Acme Iron & Metal Company, a D/B/A of Txalloy, Inc. And Mayfield Paper Company, Inc . v. Republic Waste Services of Texas, Ltd., Sometimes D/B/A Trashaway Services And Duncan Disposal

ACCEPTED
03-17-00664-CV
21589869
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/3/2018 4:38 PM
JEFFREY D. KYLE
CLERK
No. 03-17-00664-CV

FILED IN
IN THE COURT OF APPEALS 3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE THIRD DISTRICT 1/3/2018 4:38:55 PM
AUSTIN, TEXAS JEFFREY D. KYLE
Clerk

ACME IRON & METAL COMPANY, A D/B/A OF TXALLOY, INC.; and
MAYFIELD PAPER,
Appellants,
v.
REPUBLIC WASTE SERVICES OF TEXAS, LTD., SOMETIMES D/B/A
TRASHAWAY SERVICES; AND DUNCAN DISPOSAL,
Appellee.

APPELLANTS’ UNOPPOSED
MOTION FOR EXTENSION OF TIME
TO FILE INITIAL BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

Appellants Acme Iron & Metal Company, a d/b/a Of Txalloy, Inc.; and

Mayfield Paper (“Appellants”) hereby move the Court for an extension of time of

thirty (30) days for the filing of their initial brief in the above-captioned action.

The current due date for Appellants’ brief is January 2, 2018. Appellants

respectfully request a thirty (30) day extension of the due date, to Thursday,

February 1, 2018.
 Appellants request this extension of time pursuant to Texas Rule of

Appellate Procedure 38.6(d), due to numerous filing and other deadlines

Appellants’ counsel has in other cases and the intervening holidays. Appellants

have not requested an extension of time previously. Counsel for Appellants has

inquired as to whether Appellee will oppose this motion, and counsel for Appellee

has stated that the motion is not opposed.

Prayer
Appellants respectfully request that the Court grant their Unopposed Motion

for Extension of Time to File Initial Brief, making that brief due February 1, 2018.

Respectfully submitted,

GRAVES, DOUGHERTY, HEARON & MOODY, P.C.
401 Congress Avenue, Suite 2200
Austin, Texas 78701
(512) 480-5600 phone

/s/ James A. Hemphill
James A. Hemphill
State Bar No. 00787674
jhemphill@gdhm.com
Direct Phone: (512) 480-5762
Direct Fax: (512) 536-9907
jhemphill@gdhm.com
Christopher L. Elliott
State Bar No. 06535400
celliott@gdhm.com
David A. King
State Bar No. 24083310
dking@gdhm.com

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 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served on
the following counsel for Appellee via electronic service, with a courtesy copy via
email, on the 3rd day of January, 2018:

Don W. Griffis
Jackson Walker L.L.P.
301 West Beauregard Ave., Suite 200
San Angelo, Texas 76903
via email: dgriffis@jw.com

Charles L. Babcock
Patrick R. Cowlishaw
John K. Edwards
Edwin Buffmire
Jackson Walker L.L.P.
2323 Ross Avenue, Suite 600
Dallas, Texas 75201
via email:
cbabcock@jw.com; pcowlishaw@jw.com; jedwards@jw.com; ebuffmire@jw.com

Connie Pfeiffer
Beck Redden LLP
1221 McKinney Street, Suite 4500
Houston, Texas 77010
via email: cpfeiffer@beckredden.com

/s/ James A. Hemphill
James A. Hemphill

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