ACCEPTED
03-17-00483-CV
21101006
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/5/2017 4:25 PM
JEFFREY D. KYLE
CLERK
No. 03-17-00483-CV
IN THE THIRD COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
12/5/2017 4:25:08 PM
INTEGRITY Global Security, LLC and Green Hills Software, Inc.,
JEFFREY D. KYLE
Clerk
Appellants,
v.
Dell Marketing L.P., Dell Federal Systems L.P., and Dell Products, L.P.,
Appellees.
On Appeal from the 345th Judicial District Court, Travis County, Texas
Trial Court Cause No. D-1-GN-16-000345
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ REPLY BRIEF
Dale Wainwright Frank E. Merideth, Jr.
State Bar No. 00000049 Admitted Pro Hac Vice
wainwrightd@gtlaw.com meridethf@gtlaw.com
Alan W. Hersh GREENBERG TRAURIG, LLP
State Bar No. 24080944 1840 Century Park East, Suite 1900
hersha@gtlaw.com Los Angeles, California 90067
GREENBERG TRAURIG, LLP Telephone: (310) 586-7825
300 West 6th Street, Suite 2050 Facsimile: (310) 586-0275
Austin, Texas 78701
Telephone: (512) 320-7200
Facsimile: (512) 320-7210
COUNSEL FOR APPELLANTS INTEGRITY GLOBAL SECURITY, LLC AND GREEN
HILLS SOFTWARE, INC.
TO THE HONORABLE COURT:
Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(a),
Appellants INTEGRITY Global Security, LLC and Green Hills Software, Inc.
(collectively “Appellants”) file this unopposed motion requesting an extension of
time to file their reply brief, which is currently due on December 11, 2017.
Appellants seek a thirty day extension, up to an including January 10, 2018, in
which to file their reply brief. This is Appellants’ first request for an extension of
this deadline. Appellees do not oppose the requested extension.
Appellants request this extension to allow appellate counsel an opportunity
to fully analyze and respond to the issues presented in Appellees’ response brief.
The Court previously granted Appellees’ unopposed motion for a 30-day extension
in which to file their Appellees’ Brief. Appellees’ Brief is nearly sixty pages long,
excluding appendices, and Appellants require additional time to adequately and
fully respond to the complex issues presented in this appeal.
Furthermore, commitments in trial courts and other appellate deadlines—as
well as personal commitments during the holiday season—facing Appellants’
counsel make additional time to adequately prepare and file Appellants’ reply
necessary. Therefore, Appellants requests that the Court grant this thirty day
extension in order to afford appellate counsel adequate time to thoroughly reply to
the complex issues and arguments raised.
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This extension is not sought for purposes of delay but that justice may be
done.
PRAYER
For these reasons, Appellants INTEGRITY Global Security, LLC and Green
Hills Software, Inc. pray that the Court grant Appellants’ motion for a thirty day
extension of time, allowing Appellants up to and including January 10, 2017, to
reply to Appellees’ Brief. Appellants also pray for such further relief to which
they may be entitled.
Respectfully submitted,
GREENBERG TRAURIG, LLP
By: /s/ Dale Wainwright By: /s/ Frank E. Merideth, Jr.
Dale Wainwright Frank E. Merideth, Jr.
State Bar No. 00000049 California State Bar No. 46266
wainwrightd@gtlaw.com Admitted Pro Hac Vice
Alan W. Hersh 1840 Century Park East, Suite 1900
State Bar No. 24080944 Los Angeles, CA 90067-2101
hersha@gtlaw.com Telephone: (310) 586-7879
300 West 6th Street, Suite 2050 Facsimile: (310) 586-0275
Austin, Texas 78701 meridethf@gtlaw.com
Telephone: (512) 320-7200
Facsimile: (512) 320-7210
Counsel for Appellants
INTEGRITY Global Security, LLC and Green Hills Software, Inc.
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CERTIFICATE OF CONFERENCE
I certify that I communicated about this Unopposed Motion for Extension of
Time to File Appellants’ Reply Brief with Sinead O’Carroll, counsel for Appellees,
and she advised that they do not oppose the relief requested in this motion.
/s/ Alan Hersh
Alan Hersh
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was
electronically filed with the Court and that counsel of record, who are deemed to
have consented to electronic service, are being served on this 5th day of December
2017 via the court’s CM/ECF System.
Beverly Reeves
State Bar No. 16716500
breeves@reevesbrightwell.com
Kim Brightwell
State Bar No. 02992700
kbrightwell@reevesbrightwell.com
Sinead O’Carroll
State Bar No. 24013253
socarroll@reevesbrightwell.com
REEVES & BRIGHTWELL LLP
221 W. 6th Street, Suite 1000
Austin, Texas 78701
Phone: (512) 334-4500
Facsimile: (512) 334-4492
Counsel for Defendants
Dell Marketing L.P.,
Dell Federal Systems L.P., and
Dell Products L.P.
/s/ Dale Wainwright
Dale Wainwright
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Integrity Global Security, LLC And Green Hills Software, Inc. v. Dell Marketing L.P., a Texas Limited Partnership, Dell Federal Systems, L.P., a Texas Limited Partnership And Dell Products, L.P., a Texas Limited Partnership
Combined Opinion