ACCEPTED
03-14-00375-CV
6671000
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/26/2015 6:03:02 PM
JEFFREY D. KYLE
No. 03-14-00375-CV CLERK
In the FILED IN
3rd COURT OF APPEALS
Third Court of Appeals AUSTIN, TEXAS
8/26/2015 6:03:02 PM
Austin, Texas JEFFREY D. KYLE
Clerk
_______________
AUSPRO ENTERPRISES, LP,
Appellant,
v.
TEXAS DEPARTMENT OF TRANSPORTATION,
Appellee.
_______________
On Appeal from the 345th Judicial District Court of
Travis County, Texas
_______________
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
SUPPLEMENTAL REPLY ON REED V. TOWN OF GILBERT
_______________
Meredith B. Parenti
State Bar No. 00797202
PARENTI LAW PLLC
7500 San Felipe, Suite 600
Houston, Texas 77063
[Tel] (281) 224-5848
[Fax] (281) 605-5677
meredith@parentilaw.com
Counsel for Appellant
AusPro Enterprises, LP
I DENTITIES OF P ARTIES AND C OUNSEL
The following is a complete list of the parties, attorneys, and any other
person who has any interest in the outcome of this appeal.
Defandant/Appellant:
AusPro Enterprises, LP
Counsel for Defendant/Appellant:
Meredith B. Parenti
State Bar No. 00797202
PARENTI LAW PLLC
7500 San Felipe, Suite 600
Houston, Texas 77063
[Tel] (281) 224-5848
[Fax] (281) 605-5677
meredith@parentilaw.com
Plaintiff/Appellee:
Texas Department of Transportation
Counsel for Plaintiff/Appellee:
Douglas Geyser
Assistant Solicitor General
Matthew Bohuslav
Assistant Attorney General, Transportation Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
[Tel] (512) 936-2540
[Fax] (512) 472-3855
douglas.geyser@texasattorneygeneral.gov
matthew.bohuslav@texasattorneygeneral.gov
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TO THE HONORABLE THIRD COURT OF APPEALS:
Appellant AusPro Enterprises, LP files this unopposed motion for a
30-day extension of time in which to file Appellant’s Supplemental Reply on
Reed v. Town of Gilbert, which is currently due on September 8, 2015.
Counsel for Appellant has several upcoming deadlines in other cases,
including responses and reply briefing in Grupo Mexico, S.A.B. de C.V. v.
SAS Asset Recovery, Ltd., Misc. Action No. 3-14 MC-073-G-BH, in the
United States District Court for the Northern District of Texas and No. 15-
10300, in the United States Court of Appeals for the Fifth Circuit; response
briefing in Martin v. Andrews Kurth LLP, No. 2013-61098, in the District
Court of Harris County, Texas; and an amicus brief in Fisher v. University of
Texas, No. 14-981, in the Supreme Court of the United States. As a result,
counsel needs additional time to prepare AusPro’s supplemental reply
addressing the impact of the Supreme Court’s decision in Reed on this case.
Appellant has not requested any previous extensions of time to file the
supplemental reply. The Court granted three previous requests for extension
of time to file AusPro’s opening brief. Appellee Texas Department of
Transportation does not oppose this request for an extension. This extension
is not sought for delay, and no party will be prejudiced if it is granted. With
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a 30-day extension, Appellant’s supplemental reply would be due on
October 8, 2015.
PRAYER
For the above reasons, Appellant respectfully requests a 30-day
extension of time to file its supplemental reply on Reed.
Respectfully submitted,
/s/ Meredith B. Parenti
Meredith B. Parenti
PARENTI LAW PLLC
7500 San Felipe, Suite 600
Houston, Texas 77063
Tel: (281) 224-5848
Fax: (281) 605-5677
meredith@parentilaw.com
Counsel for Appellant
AusPro Enterprises, LP
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CERTIFICATE OF CONFERENCE
I certify that on August 26, 2015, I conferred with counsel for
Appellee, who represented that Appellee does not oppose this motion.
/s/ Meredith B. Parenti
Meredith B. Parenti
CERTIFICATE OF SERVICE
I certify that on August 26, 2015, I served by a copy of this Motion on
the following party via email and through the Court’s electronic filing
system:
Douglas Geyser
Assistant Solicitor General
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Counsel for Appellee Texas Department of Transportation
/s/ Meredith B. Parenti
Meredith B. Parenti
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