NO. 03-11-00462

In The 

Third Court of Appeals

AT AUSTIN, TEXAS

Sanadco Inc., Mahmoud A. Isba, Walid Abderrahman, Majic Investments 

Inc., Faisal Khan, Isra Enterprises, Inc., Hattab Al-Shudifat, Haifa 

Enterprises, Inc., EID Corp., Mohammed S. Al Hajeid, Majdi Rafe Okla 

Nsairat, Omar Unlimited, Inc., and All Others Similarly Situated,

APPELLANTS

VS.

The Office of the Comptroller of Public Accounts; Susan Combs, in her 

individual and official capacities as Comptroller of Public Accounts for 

the State of Texas; and Greg Abbott in his official capacity as Attorney 

General of the State of Texas

APPELLEES

__________________________________________________________

Appeal From Cause No D-1-GV-10-000902

The 98th District Court Of Travis County, Texas

The Honorable Tim Sulak, Presiding

__________________________________________________________

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANTS’ FURTHER MOTION FOR REHEARING 

___________________________________________________________

TO THE HONORABLE THIRD COURT OF APPEALS:

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

49.8, move this Honorable Court to extend the time for filing its Further Motion 

for Rehearing, and for cause would show unto the Court the following:

ACCEPTED

03-11-00462-CV

4853756

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/11/2015 11:47:37 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 4/13/2015 12:00:00 AM JEFFREY D. KYLE Clerk
1. This Court issued its judgment and opinion on Rehearing in this cause on

March 25, 2015, reversing its opinion of September 26, 2013 on other

grounds. Accordingly, the Further Motion for Rehearing is currently due on

April 9, 2015. Petitioners request a 30-day extension, creating a new

deadline of May 9, 2015.

2. Counsel for Appellants is a semi-retired solo practitioner with a home office

practice and no staff, who maintains a limited practice due to a heart

condition and diabetes. This extension of time is being requested because

Appellants have had insufficient time to prepare the Further Motion for

Rehearing due to illness and the extensive research required as a result of the

court’s reversal on grounds which had not previously been considered by the

court or briefed by the Appellants.

3. In addition, counsel is involved in the preparation of an expedited appeal in

Case No. 03-14-00771-CV, filed in this Court on December 3, 2014 from a

judgment entered in Cause No. D-1-GN-13- 04352 on November 13, 2014

and is due on Monday, April 13, 2015. He is also preparing an as yet unfiled

Petition for Writ of Mandamus to this Court from a judgment entered in

Cause No. D-1-GN-12-003918 on October 23, 2014.

4. For these reasons, Appellants respectfully request that the Court

grant a 30-day extension of time for filing this Further Motion for

Rehearing, creating a new deadline of May 9, 2015.

5. This is the first motion for extension of time for filing the Further Motion for

Rehearing in this cause.
6. This motion is not being sought for delay, but so that the interests of justice

may be served.

WHEREFORE, PREMISES CONSIDERED, Petitioners respectfully move

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

for filing the Further Motion for Rehearing in this cause to May 9, 2015.

Respectfully submitted,

Law Office of 

Samuel T. Jackson

__/s/ Samuel T Jackson

Texas Bar No. 10495700

PO Box 170633

Arlington, TX 76003-0633

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 April

10, 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