NO. 03-14-00771-CV

 

In The 

Third Court of Appeals 

AT AUSTIN, TEXAS 

Sanadco Inc., Mahmoud A. Isba, Broadway Grocery, Inc., Shariz, Inc., 

Ruby & Sons Store, Inc., and Rubina Noorani,

APPELLANTS

VS. 

The Office of the Comptroller of Public Accounts; Glenn Hegar, in his

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 

__________________________________________________________ 

Appeal From Cause No D-1-GN-13-4352 

The 200th District Court Of Travis County, Texas 

The Honorable Charles Ramsay, Presiding 

__________________________________________________________ 

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANTS’ BRIEF IN ACCELERATED APPEAL 

___________________________________________________________ 

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 200th District Court issued its order 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

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 2/24/2015 2:53:05 PM JEFFREY D. KYLE Clerk
Sanadco Inc. and Mahmoud A. Isba, Et Al vs.

The Comptroller of Public Accounts, Et Al

2

and no Reporter’s Record was filed. By order of this Court, the Appellants’ brief is 

currently due on March 12, 2015. No prior motion for extension of time to file this 

brief has been requested.

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

and no staff, who maintains a limited practice complicated by diabetes and 

congestive heart failure. This extension of time is being requested because the 

undersigned counsel has not had sufficient time to prepare the Appellants’ Brief due 

to his involvement in an auto accident on December 28, 2014 resulting in counsel’s 

broken neck and rehabilitative treatments.

3. In addition, counsel is involved in the preparation of a Petition for Review in Case 

No. 15-0101 in the Texas Supreme 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 the Texas Supreme Court from a judgment entered in Cause No. D-1-

GN-12-003918 on October 23, 2014. These appeals, coupled with the normal press 

of business, have delayed preparation necessary for this appeal.

4. For these reasons, Appellants respectfully request that the Court grant a 30-

day extension of time for filing this Appellants’ Brief, creating a new deadline of

April 13, 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 of time and extend the time for filing the 

Appellants’ Brief in this cause to April 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 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 February 24, 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