NO. 03-14-00706-CV 

IN THE THIRD COURT OF APPEALS 

AUSTIN, TEXAS 

ENTERGY TEXAS, INC., 

Appellant 

v. 

PUBLIC UTILITY COMMISSION OF TEXAS, 

Appellee 

UNOPPOSED MOTION FOR EXTENSION 

 OF TIME TO FILE APPELLANT’S BRIEF 

TO THE HONORABLE THIRD COURT OF APPEALS: 

 Appellant Entergy Texas, Inc. files this motion for extension of time to file 

its reply brief in the above-referenced case. In support of the motion, Appellant 

shows as follows: 

 Appellees Public Utility Commission of Texas and Office of Public Utility 

Counsel filed their response briefs on March 6, 2015. Appellee State Agencies 

filed its response brief on March 9, 2015. Appellant’s replies to those filings are 

currently due on March 26 and 30, 2015. Appellant requests thirty-two-day 

extension of the first deadline, and a twenty-eight-day extension of the second 

deadline. Appellant has not previously sought an extension of either of these 

deadlines. If the Court grants this extension request, Appellant’s reply brief will be 

due on April 27, 2015. 

ACCEPTED

03-14-00706-CV

4511961

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/16/2015 1:50:58 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/16/2015 1:50:58 PM JEFFREY D. KYLE Clerk
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 Appellant’s counsel requires additional time to prepare ETI’s reply brief 

because counsel has had conflicting deadlines in other cases. First, the 

undersigned represents ETI in Entergy Texas, Inc. v. Public Utility Commission, 

No. 03-14-00735-CV, pending before this Court, and ETI’s appellant’s brief is due 

in that case on March 31, 2015. The undersigned also represents the petitioner in a 

case set to be orally argued at the Texas Supreme Court on March 24, 2015. See 

Kachina Pipeline Co., Inc. v. Lillis, Case No. 13-0596, in the Texas Supreme 

Court. 

Appellant is not seeking to extend the deadline for filing its brief merely for 

delay, but so that justice may be served. Accordingly, Appellant Entergy Texas, 

Inc. respectfully requests this Court extend the deadline for filing the reply brief to 

April 27, 2015. Appellant further seeks any other relief to which it may show itself 

justly entitled. 

Respectfully submitted, 

DUGGINS WREN MANN & ROMERO, LLP 

 By: /s/ Marnie A. McCormick 

Marnie A. McCormick 

State Bar No. 00794264 

mmccormick@dwmrlaw.com

P. O. Box 1149 

Austin, Texas 78767-1149 

(512) 744-9300 

(512) 744-9399 fax 
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ATTORNEYS FOR APPELLANT 

ENTERGY TEXAS, INC. 

CERTIFICATE OF CONFERENCE 

I certify that I have conferred with counsel representing all other parties, and 

they do not oppose this motion. 

 /s/ Marnie A. McCormick 

Marnie A. McCormick 

 
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CERTIFICATE OF SERVICE 

 The undersigned counsel certifies that the foregoing document was 

electronically filed with the Clerk of the Court using the electronic case filing 

system of the Court, and that a true and correct copy was served on the following 

lead counsel for all parties via electronic service on the 16th day of March, 2015: 

Elizabeth R. B. Sterling 

Environmental Protection Division 

Office of the Attorney General 

P. O. Box 12548 (MC 066) 

Austin TX 78711-2548 

Counsel for Appellee Public Utility Commission of Texas 

Rex D. VanMiddlesworth 

Benjamin Hallmark 

Thompson Knight LLP 

98 San Jacinto Blvd., Ste. 1900 

Austin TX 78701 

Counsel for Intervenor Texas Industrial Energy Consumers

Katherine H. Farrell 

Administrative Law Division 

Office of the Attorney General 

P. O. Box 12548 

Austin TX 78711-2548 

Counsel for Intervenor State Agencies

Ross Henderson 

Office of Public Utility Counsel 

1701 N. Congress Ave., Ste. 9-180 

P. O. Box 12397 

Austin TX 78711-2397 

Counsel for Intervenor Office of Public Utility Counsel

 /s/ Marnie A. McCormick 

 Marnie A. McCormick