ACCEPTED
03-15-00386-CV
6790344
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/3/2015 4:01:39 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00386-CV FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
9/3/2015 4:01:39 PM
JEFFREY D. KYLE
HARRIS COUNTY HOSPITAL DISTRICT, Clerk
Appellant,
v.
PUBLIC UTILITY COMMISSION OF TEXAS,
Appellee.
UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE APPELLEE’S BRIEF
Appellee, the Public Utility Commission of Texas, files this unopposed
motion to extend the time for filing appellee’s brief for fourteen days to
October 12, 2015.
1. The Appellee’s brief is due on September 28, 2015.
2. Appellee requests a fourteen-day extension to October 12, 2015.
3. The press of other business prevents counsel for Appellee from
preparing a brief that will be helpful to the Court by the current deadline.
Counsel attended and presented at UT’s Advanced Texas Administrative
Law Seminar August 31 and September 1, she has a long-planned and paid-
for vacation from September 9–15, 2015, and has oral argument in this
Court in Entergy Texas, Inc. v. Public Utility Commission, No. 03-14-
00735-CV on September 23, 2015. Thus, she will not be able to
substantially work on this brief until after the September 23, 2015 oral
argument.
4. This is the first request Appellee has made for an extension of
time to file appellee’s brief.
5. Counsel for Harris County Hospital District has been contacted
and does not oppose this motion for extension of time to file appellees’
brief.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
CHARLES E. ROY
First Assistant Attorney General
JAMES E. DAVIS
Deputy Attorney General for Civil Litigation
JON NIERMANN
Division Chief
Environmental Protection Division
/s/ Elizabeth R. B. Sterling
Elizabeth R. B. Sterling
Assistant Attorney General
Texas State Bar No. 19171100
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Environmental Protection Division
Office of the Attorney General
P.O. Box 12548, MC-066
Austin, Texas 78711-2548
512.463.2012
512.457-4616 FAX
Elizabeth.Sterling@texasattorneygeneral.gov
COUNSEL FOR PUBLIC UTILITY COMMISSION OF
TEXAS
Certificate of Conference
I have contacted counsel for Harris County Hospital District, the only
other party in this case. Appellant District does not oppose the motion.
/s/ Elizabeth R. B. Sterling
Elizabeth R. B. Sterling
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Certificate of Service
I hereby certify that on this the 3rd day of September 2015, a true and
correct copy of the foregoing document was served on the following counsel
electronically, through an electronic filing service, with a copy by email:
Bruce S. Powers
Harris County Assistant County Attorney
1019 Congress, 15th Floor
Houston, Texas 77002
(713) 274-5144 (telephone)
(713) 755-8924 (facsimile)
bruce.powers@cao.hctx.net
ATTORNEYS FOR HARRIS COUNTY HOSPITAL DISTRICT
/s/ Elizabeth R. B. Sterling
Elizabeth R. B. Sterling
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