No. 03-14-00713-CV



## In The Court of Appeals For the Third Judicial District Austin, Texas

S USAN C OMBS , C OMPTROLLER OF P UBLIC A CCOUNTS OF THE S TATE OF T EXAS , AND G REG A BBOTT , A

TTORNEY G ENERAL OF THE S TATE OF T EXAS ,

Appellants ,

v. CGG V ERITAS S ERVICES (U.S.), I NC ., Appellee

. On Appeal from the 353rd Judicial District Court of Travis County, Texas

A PPELLANTS ’ U NOPPOSED S ECOND M OTION FOR E XTENSION OF T IME

T O THE H ONORABLE T HIRD C OURT OF A PPEALS : In accordance with Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants Susan Combs, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas, move for an extension of time to file its brief. Appellees do not oppose motion.

I. Appellants’ brief is currently due on March 16, 2015. Appellants seek a 30-day extension, which would make its brief due on April 15, 2015. One previous extension has been granted. ACCEPTED 03-14-00713-CV 4482289 THIRD COURT OF APPEALS

AUSTIN, TEXAS 3/12/2015 4:48:23 PM JEFFREY D. KYLE

CLERK2

First, Appellants are represented by new lead couns el in this Court. Appellants’ new counsel on appeal requires time to review the r ecord and research the legal issues prior to preparing and filing the petition for revi ew. Second, Appellants’ new lead counsel has and will c ontinue to have a significant workload in other matters that will make it impossi ble to complete by the current deadline a response to the petition that will be he lpful to the Court. That workload includes reviewing the record and • drafting a motion to affirm in response to a stat ement of jurisdiction in

Evenewel v. Abbott

, No. 14-940, in the U.S. Supreme Court, due Apri l 6, and • drafting a response to Appellants’ Emergency Moti on for Stay Pending Appeal, State of Texas v. United States , No. 15-40238, in the Fifth Circuit, due in 10 day s if not expedited.

II. For each of these reasons, counsel for the Appellan ts requests additional time to review the record on appeal and analyze the relevan t law so as to provide the Court with a thorough and helpful brief.3 P RAYER Appellants respectfully requests that the Court gra nt it a 30-day extension of time to file its brief, making that brief due on April 1 5, 2015. Respectfully submitted.

K EN P AXTON Attorney General of Texas

C HARLES E. R OY First Assistant Attorney General

S COTT A. K ELLER Solicitor General

/s/ April L. Farris A PRIL L. F ARRIS Assistant Solicitor General State Bar No. 24069702

O FFICE OF THE A TTORNEY G ENERAL P.O. Box 12548 (MC 059) Austin, Texas 78711-2548 Tel.: (512) 936-2923 Fax: (512) 474-2697 april.farris@texasattorneygeneral.gov

C OUNSEL FOR A PPELLANTS4 C ERTIFICATE OF C ONFERENCE I hereby certify that on March 11, 2015 I contacte d counsel for Appellees. Counsel does not oppose this motion. /s/ April L. Farris April L. Farris

C ERTIFICATE OF S ERVICE I hereby certify that a true and correct copy of t he foregoing document has been electronically filed and served via File&ServeXpres s on March 12, 2015, to the following: Amanda Taylor State Bar No. 24045921 James F. Martens State Bar No. 13050720 Lacy Leonard State Bar No. 24040561 M ARTENS T ODD L EONARD & T AYLOR 301 Congress Ave., Suite 1950 Austin, Texas 78701 Tel.: (512) 542-9898 Fax: (512) 542-9899 ataylor@textaxlaw.com jmartens@textaxlaw.com lleonard@textaxlaw.com Counsel for Appellee /s/ April L. Farris April L. Farris