Raghunath Dass, P.E. v. Texas Board of Professional Engineers

ACCEPTED
03-14-00552-CV
4109609
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/11/2015 1:52:42 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00552-CV
RAGHUNATH DASS, P. E., ˜ IN THE THIRD
Appellant, ˜ FILED IN
˜ 3rd COURT OF APPEALS
AUSTIN, TEXAS
v. ˜ COURT OF APPEALS
2/11/2015 1:52:42 PM
˜
TEXAS BOARD OF ˜ JEFFREY D. KYLE
Clerk
PROFESSIONAL ENGINEERS ˜ AUSTIN, TEXAS
Appellee. ˜

APPELLANT’S FOURTH MOTION TO EXTEND TIME TO FILE BRIEF

Appellant asks the Court to extend the time to file his brief.
A. INTRODUCTION
1. Appellant is Raghunath Dass, Ph.D., P.E.; Appellee is the Texas Board of Professional
Engineers.
2. There is no specific deadline to file this motion to extend time. See Tex. R. App. P. 38.6(d).
3. Appellant’s counsel has conferred with Appellee’s counsel, who stated that she is not
unopposed to this motion and the proposed new time to file brief for Appellant.
B. ARGUMENT & AUTHORITIES
4. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the
time to file a brief.
5. Appellant’s brief is due on February 17, 2015.
6. Appellant requests an additional 30 days to file his brief, extending the time until March 19,
2015.
7. Three previous extensions has been granted to extend the time to file Appellant’s brief.
8. Appellant needs additional time to file his brief because appellant’s attorney continuing
illness and interfering symptoms put him way behind in his work obligations, and while his
optimism caused him to project an earlier recovery and “catch up” day, he is still not yet dug out,
but is getting close to being so. Furthermore, Appellant has recently retained another attorney to
assist Mr. Hall, a solo prctitioner, with the preparation of the brief to address the difficulty the illness
has caused. Additionally, because of unresolved confusion regarding the District Clerk’s filing a

APPELLANT’S FOURTH MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3
supplemental record as a result of the District Court’s approval of Appellant’s/Plaintiff’s Second
Amended Formal Bill of Exception, Appellant is still trying to get this issue settled, for this
supplement to the record is necessary for the preparation of Appellant’s brief.
C. CONCLUSION
9. Appellant is requesting an extension of time to file his brief so that appellant’s attorney has
sufficient to time to prepare his brief in a competent and clear manner.
D. PRAYER
10. For these reasons, Appellant asks the Court to grant an extension of time to file his brief until
March 19, 2015.
Respectfully submitted,

JIMMY ALAN HALL, PLLC
4600 Mueller Boulevard, Suite 2121
Austin, Texas 78723-3372
Telephone: 512-722-3190
Telecopier: 512-857-9195
jahall@fbjah.com

State Bar No.08759800

ATTORNEY FOR APPELLANT

APPELLANT’S FOURTH MOTION TO EXTEND TIME TO FILE BRIEF Page 2 of 3
 CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant’s Fourth Motion to
Extend Time to File Brief has been sent in accordance with the Texas Rules of Appellate Procedure
by electronic service on this 11th day of February, 2015, to:

Jennifer L. Hopgood
Assistant Attorney General
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-1660
Facsimile: (512) 320-0167
jennifer.hopgood@texasattorneygeneral.gov

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