ACCEPTED
03-14-00771-CV
5841094
THIRD COURT OF APPEALS
AUSTIN, TEXAS
6/26/2015 12:47:22 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00771-CV
FILED IN
In The 3rd COURT OF APPEALS
AUSTIN, TEXAS
Third Court of Appeals 6/26/2015 12:47:22 PM
JEFFREY D. KYLE
AT AUSTIN, TEXAS Clerk
Sanadco Inc., Mahmoud A. Isba, Broadway Grocery, Inc., Shariz, Inc.,
Ruby & Sons Store, Inc., and Rubina Noorani,
APPELLANTS
VS.
The Office of the Comptroller of Public Accounts; Glenn Hegar, in his
individual and official capacities as Comptroller of Public Accounts for
the State of Texas; and Ken Paxton in his official capacity as Attorney
General of the State of Texas,
APPELLEES
__________________________________________________________
Appeal From Cause No D-1-GN-13-4352
The 200th District Court Of Travis County, Texas
The Honorable Charles Ramsay, Presiding
__________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ REPLY BRIEF
___________________________________________________________
TO THE HONORABLE THIRD COURT OF APPEALS:
Appellants, SANADCO, INC. ET AL, pursuant to TEX. R. APP. P. 38.6 (d) and 10.5 (b), move
this Honorable Court to extend the time for filing its Appellant’s Reply Brief, and for cause
would show unto the Court the following:
1. The 200th District Court issued its order denying Appellants’ motion for temporary
orders in Cause No. D-1-GN-13-4352 on November 13, 2014. On December 3, 2014,
Appellants timely filed a Notice of Accelerated Appeal from an Interlocutory Order
Denying a Temporary Injunction. The clerk filed her record on January 6, 2015, and
the Reporter did not file a record.
2. After a grant of a motion for extension of time, Appellants timely filed its brief on
April 16, 2015, and Appellees, after the grant of its motion for extension of time,
filed their timely Response on May 26, 2015.
3. On June 16, 2016, Appellants inadvertently submitted their untimely Reply Brief,
having been due on June 15, 2015 pursuant to Rule 38.6 (c). Appellants, after
inquiry, were advised on June 26, 2015, that a motion for new trial would be
required before the brief could be filed.
4. For these reasons, Appellants respectfully request that the Court grant a 12-
day extension of time for filing this Appellants’ Brief, creating a new deadline of
June 27, 2015.
5. This motion is not being sought for delay, but so that the interests of justice may be
served.
WHEREFORE, PREMISES CONSIDERED, Appellants respectfully move this
Honorable Court to grant this motion for extension of time and extend the time for filing the
Appellants’ Reply Brief in this cause to June 27, 2015.
Respectfully submitted,
Law Office of
Samuel T. Jackson
__/s/ Samuel T Jackson
Texas Bar No. 10495700
PO Box 170633
Arlington, TX 76003-0633
Sanadco Inc. and Mahmoud A. Isba, Et Al vs. 2
The Comptroller of Public Accounts, Et Al
Motion for Extension of Time
Tel: (512) 692-6260
Fax. 866 -722-9685
jacksonlaw@hotmail.com
ATTORNEY FOR APPELLANTS
CERTIFICATE OF CONFERENCE
I hereby certify that counsel for the parties have conferred concerning this request for
extension of time, and counsel for the Appellees does not oppose this motion.
_/s/ Samuel T Jackson
Samuel T. Jackson
CERTIFICATE OF SERVICE
By my signature above, I hereby certify that a true and correct copy of the above and
foregoing instrument was served on the parties or their attorneys via facsimile, certified mail,
return receipt requested, and/or hand delivery on June 26, 2015, in accordance with the Texas
Rules of Appellate Procedure, to the following:
JACK HOHENGARTEN
Assistant Attorney General
FINANCIAL LITIGATION DIVISION
P.O. Box 12548
Austin, TX 78711-2548
Tel: (512) 475-3503
Fax: (512) 477-2348/480-8327
Email: jack.hohengarten@oag.state.tx.us
Sanadco Inc. and Mahmoud A. Isba, Et Al vs. 3
The Comptroller of Public Accounts, Et Al
Motion for Extension of Time