NO. 03-14-00771-CV

 

In The 

Third Court of Appeals 

AT AUSTIN, TEXAS 

Sanadco Inc., Mahmoud A. Isba, Broadway Grocery, Inc., Shariz, Inc., 

Ruby & Sons Store, Inc., and Rubina Noorani,

APPELLANTS

VS. 

The Office of the Comptroller of Public Accounts; Glenn Hegar, in his 

individual and official capacities as Comptroller of Public Accounts for 

the State of Texas; and Ken Paxton in his official capacity as Attorney 

General of the State of Texas, 

APPELLEES 

__________________________________________________________ 

Appeal From Cause No D-1-GN-13-4352 

The 200th District Court Of Travis County, Texas 

The Honorable Charles Ramsay, Presiding 

__________________________________________________________ 

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANTS’ REPLY BRIEF 

___________________________________________________________ 

TO THE HONORABLE THIRD COURT OF APPEALS: 

Appellants, SANADCO, INC. ET AL, pursuant to TEX. R. APP. P. 38.6 (d) and 10.5 (b), move 

this Honorable Court to extend the time for filing its Appellant’s Reply Brief, and for cause 

would show unto the Court the following: 

1. The 200th District Court issued its order denying Appellants’ motion for temporary 

orders in Cause No. D-1-GN-13-4352 on November 13, 2014. On December 3, 2014, 

Appellants timely filed a Notice of Accelerated Appeal from an Interlocutory Order 

ACCEPTED

03-14-00771-CV

5841094

THIRD COURT OF APPEALS

AUSTIN, TEXAS

6/26/2015 12:47:22 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 6/26/2015 12:47:22 PM JEFFREY D. KYLE Clerk
Sanadco Inc. and Mahmoud A. Isba, Et Al vs.

The Comptroller of Public Accounts, Et Al

Motion for Extension of Time

2

Denying a Temporary Injunction. The clerk filed her record on January 6, 2015, and 

the Reporter did not file a record. 

2. After a grant of a motion for extension of time, Appellants timely filed its brief on 

April 16, 2015, and Appellees, after the grant of its motion for extension of time,

filed their timely Response on May 26, 2015.

3. On June 16, 2016, Appellants inadvertently submitted their untimely Reply Brief, 

having been due on June 15, 2015 pursuant to Rule 38.6 (c). Appellants, after 

inquiry, were advised on June 26, 2015, that a motion for new trial would be 

required before the brief could be filed.

4. For these reasons, Appellants respectfully request that the Court grant a 12-

day extension of time for filing this Appellants’ Brief, creating a new deadline of

June 27, 2015.

5. This motion is not being sought for delay, but so that the interests of justice may be 

served.

WHEREFORE, PREMISES CONSIDERED, Appellants respectfully move this 

Honorable Court to grant this motion for extension of time and extend the time for filing the 

Appellants’ Reply Brief in this cause to June 27, 2015.

Respectfully submitted,

Law Office of 

Samuel T. Jackson 

__/s/ Samuel T Jackson

Texas Bar No. 10495700

PO Box 170633

Arlington, TX 76003-0633
Sanadco Inc. and Mahmoud A. Isba, Et Al vs.

The Comptroller of Public Accounts, Et Al

Motion for Extension of Time

3

Tel: (512) 692-6260

Fax. 866 -722-9685

jacksonlaw@hotmail.com

ATTORNEY FOR APPELLANTS

CERTIFICATE OF CONFERENCE

I hereby certify that counsel for the parties have conferred concerning this request for 

extension of time, and counsel for the Appellees does not oppose this motion.

_/s/ Samuel T Jackson

Samuel T. Jackson

CERTIFICATE OF SERVICE

By my signature above, I hereby certify that a true and correct copy of the above and 

foregoing instrument was served on the parties or their attorneys via facsimile, certified mail, 

return receipt requested, and/or hand delivery on June 26, 2015, in accordance with the Texas 

Rules of Appellate Procedure, to the following:

JACK HOHENGARTEN 

Assistant Attorney General 

FINANCIAL LITIGATION DIVISION 

P.O. Box 12548 

Austin, TX 78711-2548 

Tel: (512) 475-3503 

Fax: (512) 477-2348/480-8327 

Email: jack.hohengarten@oag.state.tx.us