Case No. 03-13-00196-CV Appellant’s Motion to Extend Time to File Motion for Rehearing 

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No. 03-13-00196-CV

THIRD COURT OF APPEALS 

AUSTIN, TEXAS

MICHELLE BUBNIS, Appellant

V.

LEANDER I.S.D., Appellee

On Review from the 126th District Court of Travis County 

Cause No. D-1-GV-09-001868, the Honorable Tim Sulak Presiding 

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME 

TO FILE A MOTION FOR REHEARING

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: 

Appellant, Michelle Bubnis, respectfully asks this Honorable Court to 

extend the time to file Appellant’s Motion for Rehearing. 

A. Introduction 

1. The Appellant is Michelle Bubnis, an injured school teacher and former citizen 

of Texas who resided in the Travis County, Texas at the time of her accident; 

and the Respondent is the Leander Independent School District, a political 

subdivision treated as a workers’ compensation insurance carrier in Texas. 

2. This Court issued its decision on March 25, 2015. 

ACCEPTED

03-13-00196-CV

4835220

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/9/2015 5:42:41 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 4/9/2015 5:42:41 PM JEFFREY D. KYLE Clerk
Case No. 03-13-00196-CV Appellant’s Motion to Extend Time to File Motion for Rehearing

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3. This motion is filed on April 9, 2015, the current due date and within the 

time to file a motion to extend time, as required by Texas Rules of Appellate 

Procedure including Rule 49.8

4. Lead counsel for Respondent is unopposed to this motion.

B. Argument & Authorities

5. This Court has authority under Rule 49.8 to grant Appellant additional 

time to file Appellant’s Motion for Rehearing

6. This matter is a pro bono appeal.

7. This Court issued its decision on March 25, 2015, and this makes the 

rehearing due on April 9, 2015.

8. Appellant requests an additional 30 days from April 9, 2015 to file the 

Appellant’s Brief, extending the time until Saturday, May 9, 2015, which would 

extend the due date until Monday May 11, 2015.

9. One previous unopposed extension has been granted to extend time to 

file the Appellant’s Brief, and Appellee is unopposed to this extensions.

10. Appellant needs additional time to file the Appellant’s Brief because:

a. Counsel for Appellant has been involved with other judicial and 

administrative proceedings in the last month and continuing into the next. 

Appellant’s counsel has also had previously set family and children’s 
Case No. 03-13-00196-CV Appellant’s Motion to Extend Time to File Motion for Rehearing

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educational and extracurricular commitments in the last month and extending

into this month. Appellant’s counsel is of counsel to a very small law firm, and 

counsel has had an extremely heavy workload with prior deadlines and 

hearings. Included in the previous and future commitments of Appellant’s

counsel, counsel had oral argument before this Court on March 25, 2015 in 

Case No. 03-14-00012-CV. Counsel had oral argument before the Texas 

Supreme Court on March 26, 2015 in Case No. 14-0272. Counsel file a Reply 

Brief before the 5th Court of Appeals on April 2, 2015. Counsel has a Motion 

for Rehearing due on April 13, 2015, in Case 14-0256. Counsel has an 

Appellant’s Brief due on April 23, 2015 in Case No. 05-15-00195-CV before the 

5th Court of Appeals. Appellant’s counsel is also currently lead counsel of 

record in District Court matters in Travis County, Harris County, Edinburgh 

County, Rockwall County, Martin County and other counties. 

b. Because the Appellant’s Motion for Rehearing is currently due on April 

9, 2015, and for the reasons contained herein, Appellant is filing this Motion to 

Extend Time to File the Appellant’s Motion for Rehearing.

c. To be able to file the succinctly and adequately file the Appellant’s

Motion for Rehearing in this significant workers’ compensation matter an 

additional 30 days is requested, and not additional extensions are anticipated.
Case No. 03-13-00196-CV Appellant’s Motion to Extend Time to File Motion for Rehearing

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C. Conclusion

This unopposed motion to extend time to file Appellant’s Motion for 

Rehearing is not for the purposes of delay but for time for adequate and 

succinct briefing and more time to review the record and this Court’s opininon 

and to address properly this critical workers’ compensation matter.

D. Prayer

12. For these reasons, Appellant respectfully prays and asks the Court to 

grant an extension of time of 30 days, plus one two day, until Monday, May 11, 

2015, to file the Appellant’s Brief.

Respectfully,

/s/ Brad McClellan

Bradley Dean McClellan

State Bar No. 13395980

1701 Directors Blvd., Suite 110

Austin, Texas 78744

(512) 327-6884 telephone

(512) 327-8354 facsimile

Brad.McClellan@yahoo.com

Attorney for Appellant, Michelle 

Bubnis

CERTIFICATE OF CONFERENCE

I certify that I have conferred with Michael Donovan, lead counsel for Appellee by

email, and he is unopposed to the Appellant’s Motion to Extend Time to file a 

Motion for Rehearing.

/s/ Brad McClellan

Bradley Dean McClellan
Case No. 03-13-00196-CV Appellant’s Motion to Extend Time to File Motion for Rehearing

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CERTIFICATE OF SERVICE

I certify that a copy of the foregoing Appellant’s Motion to Extend Time to 

File was served on the through counsel of record by the method indicated below on 

April 9, 2015:

Michael J. Donovan

mdonovan@bajb.com

Burns Anderson Jury & Brenner, L.L.P.

P.O. Box 26300

Austin, Texas 78755-6300

512-338-5322

512-338-5363 fax

VIA efiling 

/s/ Brad McClellan

Brad McClellan