ACCEPTED
03-14-00774-CV
7846842
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/16/2015 3:01:09 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00774-CV
____________________________________________________
FILED IN
3rd COURT OF APPEALS
IN THE THIRD COURT OF APPEALS AUSTIN, TEXAS
AT AUSTIN, TEXAS 11/16/2015 3:01:09 PM
____________________________________________________
JEFFREY D. KYLE
Clerk
TEXAS STATE BOARD OF VETERINARY MEDICAL EXAMINERS, and
NICOLE ORIA, in her Official Capacity as Executive Director
Appellants/Cross-Appellees,
v.
ELLEN JEFFERSON, D.V.M.,
Appellee/Cross-Appellant.
____________________________________________________
On Appeal from the 127th Judicial District Court of Travis County, Texas
Cause No. D-1-GN-14-000287
The Honorable Gisela D. Triana presiding
_________________________________________________
APPELLEE/CROSS-APPELLANT’S UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE REPLY
____________________________________________________
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:
Appellee/Cross-Appellant, Ellen Jefferson, D.V.M., respectfully requests this Court to
grant an extension of time to file her reply to TBVME’s Suggestion of Mootness to November
20, 2015, and in support would show the Court as follows:
1. Ellen Jefferson requests an extension of time to file her reply to November 20,
2015.
2. The reason for the request is that the undersigned counsel for Ellen Jefferson has
a summary judgment opposition brief due on November 17, 2015 in Texas County and District
Retirement System v. Wexford Spectrum Fund, L.P., No. D-1-GN-13-01141 (Travis Co. Dist. Ct.).
3. This Motion is not interposed for the purpose of delay, but only for the purpose of
allowing counsel to adequately prepare and file Ellen Jefferson’s reply and fully address the
issues in TBVME’s Suggestion of Mootness.
4. This motion is unopposed.
Ellen Jefferson therefore respectfully request an extension of time to and including
November 20, 2015 in which to file and serve its reply to TBVME’s Suggestion of Mootness in
the captioned appeal.
Dated: November 16, 2015.
Respectfully submitted,
EWELL, BROWN & BLANKE LLP
____________________________________
David F. Brown
State Bar No. 03108700
dbrown@ebblaw.com
David P. Blanke
State Bar No. 02453600
dblanke@ebblaw.com
111 Congress Avenue, 28TH Floor
Austin, Texas 78701
Telephone: (512) 770-4000
Facsimile: (877) 651-6384
RYAN CLINTON
State Bar No. 24027934
rdclinton@dgclaw.com
DAVIS, GERALD & CREMER, P.C.
111 Congress Ave., Suite 1660
Austin, Texas 78701
Ph: (512) 537-9938
Fax: (432) 687-1735
ATTORNEYS FOR ELLEN JEFFERSON, D.V.M.
CERTIFICATE OF SERVICE
I certify that on November 16, 2015, this document was electronically served on Ted Ross, counsel
for the TBVME, and e-mailed to him at Ted.Ross@texasattorneygeneral.gov.
__________________________________
David P. Blanke
Texas State Board of Veterinary Medical Examiners, and Nicole Oria, in Her Official Capacity as Executive Director// Ellen Jefferson, D.V.M. v. Ellen Jefferson, D.V.M.// Texas State Board of Veterinary Medical Examiners, and Nicole Oria, in Her Official Capacity as Executive Director
Combined Opinion