Alphonso Crutch Life Support Center, Inc. v. Mike Morath, Commissioner of Education in His Official Capacity And John Doe and Jane Doe, in Their Official Capacities

ACCEPTED
03-15-00509-CV
7995768
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/25/2015 2:50:44 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00509-CV
IN THE COURT OF APPEALS
FOR THE THIRD DISTRICT OF TEXAS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
11/25/2015 2:50:44 PM
ALPHONSO CRUTCH LIFE SUPPORT CENTER,JEFFREY
INC., D. KYLE
Appellant , Clerk

v.

MICHAEL L. WILLIAMS, COMMISSIONER OF EDUCATION;
HOLLAND TIMMINS, DESIGNEE OF THE COMMISSIONER; AND
THE TEXAS EDUCATION AGENCY,

Appellees.

From the 353rd Judicial District Court of

Travis County, Texas

APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE
BRIEF

Appellant Alphonso Crutch Life Support Center, Inc. asks the court to extend

the time to file its brief.

A. Introduction

1. Appellant is Alphonso Crutch Life Support Center

2. Appellee is Michael L. Williams, et. al.

3. The deadline to file this response is December 9, 2015

4. The motion is unopposed.

B. Argument and Authorities

5. The Court has authority under TRAP 38.6 and 10.5 to extend the time
to file the brief.

6. Appellant seeks an extension to January 11th, 2016 to file the brief and

the appellee does not oppose.

7. No extension has been granted before to extend the time to file

Appellant’s brief.

8. Appellant needs additional time because of an extreme busy schedule,

including the following: the week of November 9th taking depositions for a

December arbitration; the week of November 16th serving as lead counsel in a 5 day

trial; the week of November 23rd preparing pretrial disclosures for an upcoming

arbitration and objections to witnesses and exhibits; and the undersigned counsel has

two Arbitrations scheduled in early December. One is scheduled December 1-3 and

the other December 7-11. Counsel has a deposition in another case set the next week

and then the Holidays begin.

C. Conclusion/Prayer

9. For these reasons Appellant asks the Court to grant an extension of time

to file its brief until January 11, 2015.
Respectfully submitted,

THE BLEDSOE LAW FIRM, PLLC

By:/s/ Gary L. Bledsoe
Gary L. Bledsoe
State Bar No. 02476500
garybledsoe@sbcglobal.net
Alondra Johnson
ajohnson@thebledsoelawfirm.com
State Bar No. 24087801
316 W. 12th Street
Austin, Texas 78701
(512) 322-9992 Telephone
(512) 322-0840 Fax
 CERTIFICATE OF CONFERENCE
I certify that I have conferred with Beth Klusmann by telephone and e-mail

and she has agreed and is unopposed to Appellant’s Motion to Extend Time.

/s/ Gary L. Bledsoe

Gary Bledsoe

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has

been forwarded to the following parties via e-mail/e-service, United States certified

mail and/or via facsimile on this 25th day of November 2015.

Beth Klusmann
Assistant Solicitor General
bethklusmann@texasattorneygeneral.com
(512) 936-1914

/s/ Gary L. Bledsoe
Gary Bledsoe