No. 03-15-00044-CV 

In the Court of Appeals 

for the Third Judicial District 

Austin, Texas

TEXAS DEPARTMENT OF CRIMINAL JUSTICE, 

 Appellant, 

v. 

MAURIE LEVIN, NAOMI TERR, AND HILARY SHEARD, 

 Appellees.

On Appeal from the 

201st Judicial District Court of Travis County, Texas 

UNOPPOSED MOTION TO EXTEND 

TO MAY 27, 2015, THE DEADLINE TO FILE 

APPELLANT’S OPENING BRIEF

Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6, 

Appellant Texas Department of Criminal Justice requests a 30-day 

extension of the deadline to file Appellant’s opening brief. One prior 30-

day extension of this deadline has been sought and received. This 

extension request is not opposed. 

ACCEPTED

03-15-00044-CV

4970915

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/21/2015 1:35:53 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 4/21/2015 1:35:53 PM JEFFREY D. KYLE Clerk
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The opening brief is currently due April 27, 2015. The requested 

30-day extension, if granted, would make the brief due on or before May 

27, 2015. 

There is good reason to grant the requested extension, which is not 

sought for any improper purpose. Appellant is represented by new lead 

counsel on appeal, and Appellant’s counsel has had and will continue to 

have a significant workload in other matters that makes it impossible to 

complete by the current deadline a brief that would be helpful to the 

Court. That workload includes, but is not limited to, significant 

responsibilities in the following matters: 

• Veasey v. Abbott, No. 14-41127, in the United States Court of 

Appeals for the Fifth Circuit (oral argument preparations; 

argument calendared for April 28, 2015); and 

• Ivy v. Willaims, No. 14-50037, in the United States Court of Appeals 

for the Fifth Circuit (drafting an submitting at the court’s request 

by April 23, 2015, a response to a petition for rehearing en banc in 

a class action suit for statewide injunctive and declaratory relief 

under the Americans with Disabilities Act and Section 504 of the 

Rehabilitation Act). 
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PRAYER

 For these reasons, the Court should extend to May 27, 2015, the 

deadline for filing Appellant’s opening brief. 

 

 
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 Respectfully submitted. 

 KEN A. PAXTON

 Attorney General of Texas 

 CHARLES E. ROY

 First Assistant Attorney General 

 SCOTT A. KELLER

 Solicitor General 

 /s/ Richard B. Farrer 

 RICHARD B. FARRER

 Assistant Solicitor General 

 State Bar No. 24055470 

 OFFICE OF THE ATTORNEY GENERAL

 P.O. Box 12548 (MC 059) 

 Austin, Texas 78711-2548 

 Tel.: (512) 936-1823 

 Fax: (512) 474-2697 

 richard.farrer@texasattorneygeneral.gov 

 COUNSEL FOR APPELLANT TEXAS DEPARTMENT 

 OF CRIMINAL JUSTICE
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CERTIFICATE OF CONFERENCE

 I certify that I conferred by email with counsel for Appellees, Philip 

Durst, who indicated that this motion is not opposed. 

 /s/ Richard B. Farrer 

 Richard B. Farrer 

 Counsel for Appellant 

CERTIFICATE OF SERVICE

 On April 21, 2015, the foregoing document was served via File & 

ServeXpress and e-mail on counsel for Appellees: 

Philip Durst 

Manuel Quinto-Pozos 

DEATS, DURST, OWEN & LEAVY, PLLC 

1204 San Antonio, Suite 203 

Austin, Texas 78701 

[Tel] (512) 474-6200 

[Fax] (512) 474-7896 

pdurst@ddollaw.com 

mqp@ddollaw.com 

Maurie Amanda Levin 

LAW OFFICE OF MAURIE LEVIN

614 South 4th St. #346 

Philadelphia, Pennsylvania 19147 

[Tel] (512) 294-1540 

[Fax] (215) 733-9225 

maurielevin@gmail.com 

 /s/ Richard B. Farrer 

 Richard B. Farrer 

 Counsel for Appellant