No. 03-14-00713-CV 

In The Court of Appeals 

For the Third Judicial District 

Austin, Texas

SUSAN COMBS, COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, AND 

GREG ABBOTT, ATTORNEY GENERAL OF THE STATE OF TEXAS, 

 Appellants, 

v. 

CGG VERITAS SERVICES (U.S.), INC., 

 Appellee.

On Appeal from the 

353rd Judicial District Court of Travis County, Texas 

APPELLANTS’ UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME

TO THE HONORABLE THIRD COURT OF APPEALS: 

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

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/12/2015 4:48:23 PM JEFFREY D. KYLE Clerk
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First, Appellants are represented by new lead counsel in this Court. Appellants’ 

new counsel on appeal requires time to review the record and research the legal issues 

prior to preparing and filing the petition for review. 

Second, Appellants’ new lead counsel has and will continue to have a significant 

workload in other matters that will make it impossible to complete by the current 

deadline a response to the petition that will be helpful to the Court. That workload 

includes reviewing the record and 

• drafting a motion to affirm in response to a statement of jurisdiction in 

Evenewel v. Abbott, No. 14-940, in the U.S. Supreme Court, due April 6, and 

• drafting a response to Appellants’ Emergency Motion for Stay Pending 

Appeal, State of Texas v. United States, No. 15-40238, in the Fifth Circuit, due in 10 days 

if not expedited. 

II. 

For each of these reasons, counsel for the Appellants requests additional time to 

review the record on appeal and analyze the relevant law so as to provide the Court 

with a thorough and helpful brief. 

 
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PRAYER

Appellants respectfully requests that the Court grant it a 30-day extension of time 

to file its brief, making that brief due on April 15, 2015. 

 Respectfully submitted. 

 KEN PAXTON

 Attorney General of Texas 

 CHARLES E. ROY

 First Assistant Attorney General 

 SCOTT A. KELLER

 Solicitor General 

 /s/ April L. Farris 

 APRIL L. FARRIS

 Assistant Solicitor General 

 State Bar No. 24069702 

 OFFICE OF THE ATTORNEY GENERAL

 P.O. Box 12548 (MC 059) 

 Austin, Texas 78711-2548 

 Tel.: (512) 936-2923 

 Fax: (512) 474-2697 

 april.farris@texasattorneygeneral.gov 

 COUNSEL FOR APPELLANTS

 
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CERTIFICATE OF CONFERENCE

 I hereby certify that on March 11, 2015 I contacted counsel for Appellees. 

Counsel does not oppose this motion. 

 /s/ April L. Farris 

 April L. Farris 

CERTIFICATE OF SERVICE

 I hereby certify that a true and correct copy of the foregoing document has been 

electronically filed and served via File&ServeXpress 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 

MARTENS TODD LEONARD & TAYLOR

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