Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas v. CGG Veritas Services (U.S.), Inc.

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ACCEPTED 03-14-00713-CV 4482289 THIRD COURT OF APPEALS AUSTIN, TEXAS 3/12/2015 4:48:23 PM JEFFREY D. KYLE CLERK No. 03-14-00713-CV In The Court of Appeals 3rd COURTFILED IN OF APPEALS AUSTIN, TEXAS For the Third Judicial District 3/12/2015 4:48:23 PM JEFFREY D. KYLE Austin, Texas Clerk SUSAN COMBS, COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, AND GREG ABBOTT, ATTORNEY GENERAL OF THE STATE OF TEXAS, Appellants, v. CGG VERITAS SERVICES (U.S.), INC., Appellee. On Appeal from the 353rd Judicial District Court of Travis County, Texas APPELLANTS’ UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO THE HONORABLE THIRD COURT OF APPEALS: In accordance with Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants Susan Combs, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, move for an extension of time to file its brief. Appellees do not oppose motion. I. Appellants’ brief is currently due on March 16, 2015. Appellants seek a 30-day extension, which would make its brief due on April 15, 2015. One previous extension has been granted. First, Appellants are represented by new lead counsel in this Court. Appellants’ new counsel on appeal requires time to review the record and research the legal issues prior to preparing and filing the petition for review. Second, Appellants’ new lead counsel has and will continue to have a significant workload in other matters that will make it impossible to complete by the current deadline a response to the petition that will be helpful to the Court. That workload includes reviewing the record and • drafting a motion to affirm in response to a statement of jurisdiction in Evenewel v. Abbott, No. 14-940, in the U.S. Supreme Court, due April 6, and • drafting a response to Appellants’ Emergency Motion for Stay Pending Appeal, State of Texas v. United States, No. 15-40238, in the Fifth Circuit, due in 10 days if not expedited. II. For each of these reasons, counsel for the Appellants requests additional time to review the record on appeal and analyze the relevant law so as to provide the Court with a thorough and helpful brief. 2 PRAYER Appellants respectfully requests that the Court grant it a 30-day extension of time to file its brief, making that brief due on April 15, 2015. Respectfully submitted. KEN PAXTON Attorney General of Texas CHARLES E. ROY First Assistant Attorney General SCOTT A. KELLER Solicitor General /s/ April L. Farris APRIL L. FARRIS Assistant Solicitor General State Bar No. 24069702 OFFICE OF THE ATTORNEY GENERAL P.O. Box 12548 (MC 059) Austin, Texas 78711-2548 Tel.: (512) 936-2923 Fax: (512) 474-2697 april.farris@texasattorneygeneral.gov COUNSEL FOR APPELLANTS 3 CERTIFICATE OF CONFERENCE I hereby certify that on March 11, 2015 I contacted counsel for Appellees. Counsel does not oppose this motion. /s/ April L. Farris April L. Farris CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been electronically filed and served via File&ServeXpress on March 12, 2015, to the following: Amanda Taylor State Bar No. 24045921 James F. Martens State Bar No. 13050720 Lacy Leonard State Bar No. 24040561 MARTENS TODD LEONARD & TAYLOR 301 Congress Ave., Suite 1950 Austin, Texas 78701 Tel.: (512) 542-9898 Fax: (512) 542-9899 ataylor@textaxlaw.com jmartens@textaxlaw.com lleonard@textaxlaw.com Counsel for Appellee /s/ April L. Farris April L. Farris 4