Jaguar Land Rover North America v. Board of the Texas Department of Motor Vehicles Mr. Raymond Palacios, Jr., in His Official Capacity as Chairman of the Board of the Texas Department of Motor Vehicles And Autobahn Imports, LP, D/B/A Land Rover of Fort Worth

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ACCEPTED 03-16-00770-CV 21591822 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/3/2018 5:31 PM JEFFREY D. KYLE CLERK NO. 03-16-00770-CV _____________________________________________________________ FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE THIRD DISTRICT OF TEXAS 1/3/2018 5:31:14 PM AUSTIN, TEXAS JEFFREY D. KYLE Clerk _____________________________________________________________ JAGUAR LAND ROVER NORTH AMERICA, LLC, Appellant, v. BOARD OF THE TEXAS DEPARTMENT OF MOTOR VECHICLES; MR. RAYMOND PALACIOS, JR., IN HIS OFFICIAL CAPACITY AS CHAIRMAN OF THE BOARD OF THE TEXAS DEPARTMENT OF MOTOR VEHICLES; AND AUTOBAHN IMPORTS, LP, d/b/a LAND ROVER OF FORT WORTH, Appellees. _____________________________________________________________ Direct Appeal from the Motor Vehicle Division of the Texas Department of Motor Vehicles MVD Cause No. 14-0016 LIC _____________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING OR EN BANC RECONSIDERATION __________________________________________________________________ Appellant Jaguar Land Rover North America (“JLRNA”), in accordance with Texas Rules of Appellate Procedure 2, 10.5(b), and 49.8, respectfully requests a ten-day extension on the time for it to file a motion for rehearing or en banc reconsideration of the court’s judgment of December 21, 2017. Appellees are unopposed to this motion. This Court rendered its judgment in this case, affirming in part and dismissing in part, through a memorandum opinion dated December 21, 2017. Appellant currently has until January 5, 2018 to file a motion for rehearing or a motion for en banc reconsideration. See Tex. R. App. P. 49.1, 49.7. Due to the holidays, Appellant requires additional time to fully assess the Court’s order and prepare a motion for rehearing or a motion for en banc reconsideration by the current deadline. Appellant respectfully requests an extension of ten days to allow adequate time to prepare and file one of these motions should it choose to do so. This extension would run to January 15, 2018. This is the Appellants’ first request for an extension of time regarding either motion. This request is not sought for delay, but in order that justice may be done and in order that the parties may properly review the record and adequately address the relevant questions at issue. No party will be harmed if this request for extension of time is granted; indeed, all parties are in agreement in seeking this extension. All facts recited in this motion are either in the record or within the personal knowledge of the attorney signing this motion, therefore no verification is necessary under Rule 10.2 of the Texas Rules of Appellate Procedure. 2 PRAYER Appellant respectfully requests that this Court grant Appellant’s unopposed motion for a ten-day extension of time for it to file a motion for rehearing or en banc reconsideration of the court’s judgment. Dated: January 3, 2018 Respectfully submitted, /s/ Blayne Thompson Aaron R. Crane State Bar No. 24050459 aaron.crane@hoganlovells.com Blayne Thompson State Bar No. 24088525 blayne.thompson@hoganlovells.com HOGAN LOVELLS US LLP 609 Main Street, Suite 4200 Houston, Texas 77002 Tel: (713) 632-1400 Fax: (713) 632-1401 Attorneys for Appellant Jaguar Land Rover North America, LLC 3 CERTIFICATE OF CONFERENCE I certify that I conferred with counsel for Appellees regarding this motion on January 3, 2018 and Appellees are not opposed to this motion. /s/ Blayne Thompson Blayne Thompson 4 CERTIFICATE OF SERVICE I certify that a true copy of the above was served by e-service and/or e-mail on January 3, 2018 on the following attorneys of record: Matt Dow Sarah C. Wolfe Dudley D. McCalla Assistant Attorney General Jackson Walker L.L.P. Administrative Law Division 100 Congress Ave., Suite 1100 Office of the Attorney General of Texas Austin, Texas 78701 P.O. Box 12548, Capitol Station Tel. (512) 236-2071 Austin, Texas 78711-2548 Fax (512) 691-4435 Sarah.Wolfe@oag.texas.gov mdow@jw.com dmccalla@jw.com Attorney for Appellees Board of the Texas Department of Motor Vehicles Richard W. Wiseman and Mr. Raymond Palacios, Jr., in His Padfield & Stout, LLP Official Capacity 421 W. Third Street, Suite 910 Fort Worth, Texas 76102 Tel. (817) 338-1616 Fax (817) 338-1610 rwiseman@livepad.com Attorneys for Appellee Autobahn Imports, LP /s/ Blayne Thompson Blayne Thompson 5