the County of La Salle v. Joe Weber, in His Official Capacity as Executive Director of the Texas Department of Transportation The Texas Department of Transportation Ted Houghton, in His Official Capacity as Chairman of the Texas Transportation Commission

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ACCEPTED 03-14-00501-CV 4684115 THIRD COURT OF APPEALS AUSTIN, TEXAS 3/30/2015 8:04:01 AM JEFFREY D. KYLE CLERK No. 03-14-00501-CV In the FILED IN Third Court of Appeals 3rd COURT OF APPEALS AUSTIN, TEXAS at Austin 3/30/2015 8:04:01 AM JEFFREY D. KYLE Clerk COUNTY OF LA SALLE, Appellant, v. JOE WEBER, in his official capacity as Executive Director of the Texas Department of Transportation; 
 THE TEXAS DEPARTMENT OF TRANSPORTATION; 
 TED HOUGHTON, in his official capacity as Chairman of the Texas Transportation Commission; and 
 JEFF AUSTIN III, JEFF MOSELEY, FRED UNDERWOOD, and VICTOR VANDERGRIFF, in their official capacities as Commissioners of the Texas Transportation Commission, Appellees.
 On Appeal from the 353rd District Court
 of Travis County, Texas U NOPPOSED M OTION T O E XTEND T IME FOR THE R EPLY B RIEF TO THE HONORABLE COURT OF APPEALS:
 Appellant requests a 15-day extension of time for its reply brief. The original due date was March 12, 2015. This motion requests the Court to accept the reply brief that was electronically filed on March 27, 2015. I. Appellant requests a 15-day extension on the reply brief to March 27, 2015. II. A conference was held with counsel for the Appellees on March 11, 2015 regarding the need for some extension and on March 26, 2015 about this precise length of extension. The extension is not opposed. III. Added time was needed to appropriately research and analyze the complex legal issues presented by the State Defendants. These issues took more time than expected because, in part, the procedural posture of this plea to the jurisdiction did not require the legal substance of the State Defendants’ jurisdictional arguments to be fully developed in the trial court. The extension requested will provide the Court with a reply brief appropriate to the complexity of the substantive issues. IV. These issues are of also public importance. Permitting the extension will also ensure that the Court has fully heard both sides. -2 - V. No previous extensions have been sought for this brief. VI. The Court has requested paper copies of briefs filed in this case. Paper copies of this reply brief are being filed today. VII. No party will be prejudiced by the extension sought. The Court has already scheduled the case for oral argument on April 22, 2015. VIII. The Court should grant the requested extension and accept the reply brief tendered on March 27, 2015 for filing Respectfully submitted, /s/ Don Cruse 
 Don Cruse State Bar No. 24040744 LAW OFFICE OF DON CRUSE 1108 Lavaca Street, Suite 110-436 Austin, Texas 78701 [Tel.] (512) 853-9100 [Fax] (512) 870-9002 don.cruse@texasappellate.com COUNSEL FOR APPELLANT 
 -3 - CERTIFICATE OF CONFERENCE On March 11, 2015 and March 26, 2015, I conferred with counsel for the Appellees, who informed me that the motion is not opposed. /s/ Don Cruse Don Cruse CERTIFICATE OF SERVICE I certify that on March 30, 2015, this motion was served on counsel of record electronically: Kristofer S. Monson Assistant Solicitor General P.O. Box 12548 Austin, Texas 78711-2548 Counsel for Appellees /s/ Don Cruse Don Cruse -4 -