No. 03-15-00313 

IN THE COURT OF APPEALS 

FOR THE THIRD DISTRICT OF TEXAS AT AUSTIN 

HERMENIA JENKINS, 

Appellant, 

v. 

CROSBY INDEPENDENT SCHOOL DISTRICT, and MICHAEL L. 

WILLIAMS, COMMISSIONER OF EDUCATION, 

Appellees. 

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLEE'S BRIEF 

To the Honorable Third Court of Appeals: 

In accordance with Rules 10.5(b) and 38.6(d) of the Texas Rules of 

Appellate Procedure, Appellee Crosby Independent School District ("Crosby 

ISD") requests a forty-five (45) day extension of time to file its brief. 

1. Appellant Hermenia Jenkins filed her brief on July 10, 2015. Amicus 

Curiae Texas Elementary Principals and Supervisors Association filed a brief on 

behalf of Appellant on July 10,2015. 

2. Appellee Crosby lSD's brief is currently due on August 9, 2015. A 

forty-five day extension would move the deadline to September 24, 2015. 

3. Appellee Crosby ISD has not previously requested an extension in this 

case. 

ACCEPTED

03-15-00313-CV

6313013

THIRD COURT OF APPEALS

AUSTIN, TEXAS

7/31/2015 2:40:44 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/31/2015 2:40:44 PM JEFFREY D. KYLE Clerk
4. Appellee Crosby ISD requests this extension because counsel has 

significant other professional commitments during the next 45 days. 

5. The undersigned counsel of record for the District has corresponded 

with counsel for Appellant Hermenia Jenkins and Appellee Commissioner of 

Education and they are not opposed to this motion. 

6. This extension is sought not for purposes of delay, but so that justice 

may be done. The parties and the Court will not be prejudiced by this extension of 

time. 

Therefore, Appellee Crosby Independent School District respectfully 

requests that this Court grant its motion and extend its time for filing Appellees' 

Brief from August 9,2015, to September 24,2015. 
Respectfully submitted, 

THOMPSON & HORTON LLP 

By: ___________ _ 

David B. Hodgins 

State Bar No. 09775530 

Amber K. King 

State Bar No. 24207244 

Frances R. Broussard 

State Bar No. 24055218 

3200 Southwest Freeway, Suite 2000 

Houston, Texas 77027 

Telephone: (713) 554-6766 

Facsimile: (713) 583-9397 

dhodgins@thompsonhorton.com 

aking@thompsonhorton.com 

fbroussard@thompsonhorton.com 

ATTORNEYS FOR APPELLEE CROSBY 

INDEPENDENT SCHOOL DISTRICT 
CERTIFICATE OF CONFERENCE 

I certify that on July 28, 2015 I conferred with counsel for Ms. Jenkins and 

Commissioner of Education by email and they are unopposed to this motion. 

S-Se-v 9--

DaVid B. Hodgins or Frances R. Broussard 

CERTIFICATE OF SERVICE 

I hereby certify that on the ~ l day of July, 2015, a true and correct copy of the 

above and foregoing pleading was served upon counsel of record bye-service as 

follows: 

Kevin F. Lungwitz 

The Lungwitz Law Firm, P.C. 

3005 S. Lamar Blvd. 

Suite D-I09-362 

Austin, Texas 78704-4785 

P.512.462.0188 

F.866.739.7138 

kevin@lungwitzlaw.com 

683127 

Andrew Lutostanski 

Assistant Attorney General 

Administrative Law Division 

OFFICE OF THE ATTORNEY GENERAL OF TEXAS 

P.O Box 12548, Capitol Station 

Austin, Texas 78711-2548 

P. 512.475.4200 

F.512.320.0167 

andrew.lutostanski@texasattorneygenetal.gov 

Davjd B. Hodgins 

~s~or 9-Frances R. Broussard