No. 03-14-00375-CV

In the 

Third Court of Appeals 

Austin, Texas _______________

AUSPRO ENTERPRISES, LP,

Appellant,

v.

TEXAS DEPARTMENT OF TRANSPORTATION,

Appellee.

_______________

On Appeal from the 345th Judicial District Court of 

Travis County, Texas

_______________

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

SUPPLEMENTAL REPLY ON REED V. TOWN OF GILBERT

_______________

Meredith B. Parenti

State Bar No. 00797202

PARENTI LAW PLLC

7500 San Felipe, Suite 600

Houston, Texas 77063

[Tel] (281) 224-5848

[Fax] (281) 605-5677

meredith@parentilaw.com

Counsel for Appellant 

AusPro Enterprises, LP

ACCEPTED

03-14-00375-CV

6671000

THIRD COURT OF APPEALS

AUSTIN, TEXAS

8/26/2015 6:03:02 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 8/26/2015 6:03:02 PM JEFFREY D. KYLE Clerk
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IDENTITIES OF PARTIES AND COUNSEL 

The following is a complete list of the parties, attorneys, and any other 

person who has any interest in the outcome of this appeal.

Defandant/Appellant:

AusPro Enterprises, LP

Counsel for Defendant/Appellant:

Meredith B. Parenti

State Bar No. 00797202

PARENTI LAW PLLC

7500 San Felipe, Suite 600

Houston, Texas 77063

[Tel] (281) 224-5848

[Fax] (281) 605-5677

meredith@parentilaw.com

Plaintiff/Appellee:

Texas Department of Transportation

Counsel for Plaintiff/Appellee:

Douglas Geyser

Assistant Solicitor General

Matthew Bohuslav

Assistant Attorney General, Transportation Division

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

[Tel] (512) 936-2540

[Fax] (512) 472-3855

douglas.geyser@texasattorneygeneral.gov

matthew.bohuslav@texasattorneygeneral.gov
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TO THE HONORABLE THIRD COURT OF APPEALS:

Appellant AusPro Enterprises, LP files this unopposed motion for a 

30-day extension of time in which to file Appellant’s Supplemental Reply on 

Reed v. Town of Gilbert, which is currently due on September 8, 2015. 

Counsel for Appellant has several upcoming deadlines in other cases, 

including responses and reply briefing in Grupo Mexico, S.A.B. de C.V. v. 

SAS Asset Recovery, Ltd., Misc. Action No. 3-14 MC-073-G-BH, in the 

United States District Court for the Northern District of Texas and No. 15-

10300, in the United States Court of Appeals for the Fifth Circuit; response 

briefing in Martin v. Andrews Kurth LLP, No. 2013-61098, in the District 

Court of Harris County, Texas; and an amicus brief in Fisher v. University of 

Texas, No. 14-981, in the Supreme Court of the United States. As a result, 

counsel needs additional time to prepare AusPro’s supplemental reply 

addressing the impact of the Supreme Court’s decision in Reed on this case.

Appellant has not requested any previous extensions of time to file the 

supplemental reply. The Court granted three previous requests for extension

of time to file AusPro’s opening brief. Appellee Texas Department of 

Transportation does not oppose this request for an extension. This extension 

is not sought for delay, and no party will be prejudiced if it is granted. With 
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a 30-day extension, Appellant’s supplemental reply would be due on 

October 8, 2015.

PRAYER

For the above reasons, Appellant respectfully requests a 30-day 

extension of time to file its supplemental reply on Reed.

Respectfully submitted,

/s/ Meredith B. Parenti

Meredith B. Parenti

PARENTI LAW PLLC

7500 San Felipe, Suite 600

Houston, Texas 77063

Tel: (281) 224-5848

Fax: (281) 605-5677

meredith@parentilaw.com

Counsel for Appellant 

AusPro Enterprises, LP
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CERTIFICATE OF CONFERENCE

I certify that on August 26, 2015, I conferred with counsel for 

Appellee, who represented that Appellee does not oppose this motion.

/s/ Meredith B. Parenti

Meredith B. Parenti

CERTIFICATE OF SERVICE

I certify that on August 26, 2015, I served by a copy of this Motion on 

the following party via email and through the Court’s electronic filing 

system:

Douglas Geyser

Assistant Solicitor General

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Counsel for Appellee Texas Department of Transportation

/s/ Meredith B. Parenti

Meredith B. Parenti