# NO

. 03-14 -00771- CV In The 

# Third Court of Appeals

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### AUSTIN, TEXAS Sanadco Inc., Mahmoud A. Isba, Broadway Grocery, Inc., Shariz, Inc., Ruby & Sons Store, Inc., a nd Rubina Noorani, APPELLANTS VS. The Office of the Comptroller of Public Accounts; Glenn He gar , in h is 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

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Appeal From Cause No D-1- GN

- 13 -4352 The 200 th District Court Of Travis County, Texas The Honorable Charles Ramsay, Presiding

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### UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS ’ BRIEF IN ACCELERATED APPEAL

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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 Brief, and for cause would show unto the Court the following: 1. The 2 00 th District Court issued its or der 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 Denying a Temporary Injunction

. The clerk ’ s record was filed on January 6, 2015, ACCEPTED 03-14-00771-CV 4263129 THIRD COURT OF APPEALS

AUSTIN, TEXAS 2/24/2015 2:53:05 PM JEFFREY D. KYLE

CLERKSanadco Inc. and Mahmoud A. Isba, Et Al vs.

The Comptroller of Public Accounts, Et Al 2 a nd no Repo rter ’ s Record was f iled

. B y order of this Court , the A ppe llant s ’ brief is currently due on M arch 12 , 2015

. N o prior motion for extension of time to file this brief has been requested.

2. Counsel for A p pellants is a semi

- retired solo practitioner with a home office pra ctice and no staff, who maintains a limited practice com plicated by diabetes and

c ongestive heart failure

. This extension of time is being requested because t he undersigned counsel h as not had sufficient time to prepare the A ppellants ’ Brief due
to h is involvement in an auto accident on December 28, 2014 resulting in counsel’s broken neck and r e habilitative treatments

.

3. In addition, counsel is involved in the preparation of a P etition for Re v i ew in Case No. 1 5

- 0101 in the T exas S u preme Court for which an extension of time has been granted to March 9, 2015 . He is also preparing an as yet unfiled Petition for Writ of Mandamus to t he Texas Supreme Court from a judgment entered in Cause No. D

- 1

- GN

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- 003918 on October 23, 2014. These appeals, coupled with the normal press of business, have delayed preparation necessary for this appeal.

4. For these reasons, A ppellants respectfully request that the Court grant a 30

- day extension of time for filing this A ppellants ’ Brief , creating a new deadline of April 1 3 , 2015.

5. 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 o f time and extend the time for filing the A ppellants ’ Brief in this cause to A pril 13 , 2015

. Respectfully submitted,Sanadco Inc. and Mahmoud A. Isba, Et Al vs.

The Comptroller of Public Accounts, Et Al 3 

### 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 A PPELLANTS

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 February 24, 2015 , in accordance with the Texas Rules of Appellate Procedure, to the following: JACK HOHENGARTEN Assistant Attorney General FINANCI AL LITIGATION DIVISION P.O. Box 12548 Austin, TX 78711

- 2548 T el : (512) 475

- 3503 F ax : (512) 477

- 2348/480

- 8327 Email: jack.hohengarten@oag.state.tx.us