No. 14-15-00027-CV

____________________________________________________

In the Court of Appeals

for the Fourteenth Judicial District

Houston, Texas

____________________________________________________

Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken 

Paxton, Attorney General of the State of Texas, 

Appellant,

v.

Checkfree Services Corporation,

Appellee.

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On Appeal from the 53rd Judicial District Court, Travis County, Texas

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APPELLANTS’ UNOPPOSED MOTION FOR 30-DAY EXTENSION TO 

FILE BRIEF OF APPELLANTS

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TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Pursuant to Rules 10.5 and 38.6(d) of the Texas Rules of Appellate Procedure, 

Appellants Glen Hegar, Comptroller of Public Accounts of the State of Texas, and 

Ken Paxton, Attorney General of the State of Texas ("Appellants") file this 

Unopposed Motion for a 30-day Extension to File Brief of Appellants. 

Appellants’ Brief is currently due April 15, 2015. The undersigned counsel 

respectfully requests a 30-day extension of time to file Appellants’ Brief, such that 

ACCEPTED

14-15-00027-cv

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

3/20/2015 12:01:05 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/20/2015 12:01:05 PM CHRISTOPHER A. PRINE Clerk
it would instead be due May 15, 2015. No extensions in this matter have previously 

been sought by Appellants.

The undersigned counsel relies on the following reasons, in addition to the 

routine matters that counsel must attend to in daily practice, to explain the need for 

the requested extension:

• Appellants’ prior counsel, Erika Sams, is moving out of the state. The 

undersigned counsel was not previously involved in this case, and his 

substitution of counsel was only filed on March 4, 2015.

• The undersigned counsel is responsible for reviewing numerous bills 

during the legislative session, and preparing for the Legislative Budget 

Board estimates of the fiscal impact such legislation would have upon 

his division in the Attorney General’s office.

• The undersigned counsel is lead attorney for the Texas Workforce 

Commission in numerous tax disputes, including four cases that are all

in active discovery at the present time: 

o PSM, Plus, LLC v. Tex. Workforce Comm’n et al., Cause No. D1-GN-14-00448, 53rd Judicial District Court of Travis County, 

Texas; 

o G&A Outsourcing, Inc. et al. v. Tex. Workforce Comm’n, Cause 

No. D-1-GN-14-005431, 98th Judicial District Court of Travis 

County, Texas; 

o G&A Outsourcing IV, LLC v. Tex. Workforce Comm’n, Cause 

No. D-1-GN-14-005432, 126th Judicial District Court of Travis 

County, Texas; and

o DGC Realty Solutions, LLC v. Tex. Workforce Comm’n, Cause 

No. D-1-GN-13-004087, 261st Judicial District Court of Travis 

County, Texas.

• The undersigned counsel is preparing a Plea to the Jurisdiction in 

Quinones v. Teacher Retirement Sys. of Tex. et al., Cause No. D-1-GN15-000356, 53rd Judicial District Court of Travis County, Texas, which 

will be set for hearing the week of March 30–April 3.

Appellants’ Unopposed Motion for Extension to File Brief
• The undersigned secondary counsel has a brief due on March 23, 2015 

in Hunter v. Tex. Dep’t of Ins. et al., Cause No. 03-14-00737-CV, Third 

Court of Appeals, Texas.

• The undersigned secondary counsel is the legislative liaison for her 

division at the Attorney General’s office and has extensive duties 

related to legislation during the legislative session.

• The undersigned secondary counsel will be out of the office on April 3, 

2015.

Appellants seek this extension of time to prepare a briefing that fully assists 

this Court in deciding the issues presented by this appeal. Given the undersigned 

counsels’ prior lack of involvement in this case and other time commitments, it will 

not be possible to prepare such a briefing by April 15, 2014. Appellee Checkfree 

Services Corporation is not opposed to this motion. This request is not sought for 

delay but so that justice may be done. 

PRAYER FOR RELIEF

For the reasons set forth above, Appellants request that this Court extend the 

deadline for filing Appellants’ Brief to May 15, 2015. Appellants further request all 

other relief to which they may be justly entitled.

Appellants’ Unopposed Motion for Extension to File Brief
Respectfully submitted,

KEN PAXTON

Attorney General of Texas

CHARLES E. ROY

First Assistant Attorney General

JAMES E. DAVIS

Deputy Attorney General for

Civil Litigation

ROBERT O’KEEFE

Chief, Financial Litigation, Tax, and 

Charitable Trusts Division

/s/Quinn T. Ryan

QUINN T. RYAN

Attorney-in-Charge

Financial Litigation, Tax and Charitable 

Trusts Division

State Bar No. 24074994

Tel: (512) 463-3112 

Fax: (512) 478-4013

quinn.ryan@texasattorneygeneral.gov

Cynthia A. Morales

Secondary Attorney-in-Charge

Financial Litigation, Tax, and Charitable 

Trusts Division

State Bar No. 14417420

P.O. Box 12548

Austin, Texas 78711-2548

Tel: (512) 475-4470

Fax: (512) 478-4013

cynthia.morales@texasattorneygeneral.gov

Attorneys for Appellants

Appellants’ Unopposed Motion for Extension to File Brief
CERTIFICATE OF CONFERENCE 

I certify that on March 18, 2015, I conferred with counsel for Appellee by 

email, who confirmed that Appellee is not opposed to this motion.

CERTIFICATE OF SERVICE

I certify that on March 20, 2015, a copy of this Appellants’ Unopposed Motion 

for 30-Day Extension to File Brief of Appellants was served on Appellee as indicated 

below:

Doug Sigel

RYAN LAW FIRM, LLP

Counsel for Appellee

Via e-serve: doug.sigel@ryanlawllp.com

/s/Quinn T. Ryan

QUINN T. RYAN

Assistant Attorney General

Appellants’ Unopposed Motion for Extension to File Brief