ACCEPTED

03-15-00078-CV

4960128

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/20/2015 4:44:55 PM

JEFFREY D. KYLE

CLERK

NO. 03-15-00078-CV 

IN THE COURT OF APPEALS 

FOR THE THIRD DISTRICT OF TEXAS, 

AT AUSTIN, TEXAS 

CHRIS BELL, 

Appellant, 

v. 

REPUBLICAN GOVERNORS ASSOCIATION 

Appellee 

From 261st District Court, 

Travis County, Texas 

UNOPPOSED FIRST MOTION TO EXTEND TIME TO 

FILE APPELLEE'S BRIEF 

TO THE HONORABLE THIRD COURT OF APPEALS: 

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), Appellee Republican 

Governors Association files this Unopposed First Motion to Extend Time to File 

Appellee's Brief, and would respectfully show as follows: 

1. Appellee's response brief is currently due on April27, 2015. 

2. Counsel for Appellee requests a 14-day extension of time to file its 

brief, making the brief due on May 11, 2015. This is the first request for extension 

of time to file the response brief. 
3. Counsel for Appellee relies on the following reasons, in addition to 

the routine matters that counsel must attend to in daily practice, to explain the need 

for the requested extension: 

1. Counsel's litigation and appellate practice consists of two 

attorneys. Currently, one of said attorneys is out on maternity leave, which 

in-tum limits the amount of time available to counsel to draft its response 

brief and attend to the other matters for which it is responsible. Several of 

Counsel's other matters require immediate attention this week, further 

limiting the time available to Counsel to draft its response brief. 

4. Therefore, Counsel for Appellee seeks this extension of time to be 

able to prepare a cogent and succinct brief to aid this Court in its analysis of the 

issues presented. This request is not sought for delay but so that justice may be 

done. 

5. The undersigned has conferred with opposing counsel, and he has 

indicated that his client does not oppose this motion. 

6. All facts recited in this motion are within the personal knowledge of 

the counsel signing this motion, therefore no verification is necessary under Rule 

of Appellate Procedure 1 0.2. 
-------------------- ------------- --------------------

PRAYER FOR RELIEF 

For the reasons set forth above, Appellee requests that this Court grant this 

Unopposed First Motion to Extend Time to File Appellee's Response Brief and 

extend the Deadline for Filing the Appellee's Response Brief to May 11, 2015. 

Respectfully submitted, 

Respectfully submitted, 

HANCESCARBOROUGH,LLP 

400 W. 15th Street, Suite 950 

Austin, Texas 78701 

Telephone: (512) 479-8888 

Facsimile: (512) 482-6891 

car borough 

State ar No. 17716000 

V. Blayre Pefia 

State Bar No. 24050372 

ATTORNEYS FOR DEFENDANT 

REPUBLICAN GOVENORS ASSOCIATION 
-------------------

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing document has 

been forwarded to all counsel of record herein by facsimile on this the 20th day of 

April, 20 15. 

VIA FACSIMILE 

Tom H. Watkins 

Rusch Blackwell 

111 Congress Avenue, Suite 1400 

Austin, Texas 78701-4093 

Telephone: (512) 703-5752 

Facsimile: (512) 479-1101 

Randall B. Wood 

RAY, WOOD&BONILLA 

2700 Bee Caves Road, Suite 200 

Austin, Texas 78746 

Telephone: (512) 328-8877 

Facsimile: (512) 328-1156