NO. 03-14-00552-CV

IN THE COURT OF APPEALS 

FOR THE THIRD JUDICIAL DISTRICT AT AUSTIN, TEXAS 

___________________________________ 

RAGHUNATH DASS, P.E., 

Appellant, 

v.

TEXAS BOARD OF PROFESSIONAL ENGINEERS, 

Appellee. 

___________________________________ 

On Appeal from the 

201st Judicial District Court, Travis County, Texas 

___________________________________ 

UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF 

_____________________________________ 

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: 

 Now comes Appellee, Texas Board of Professional Engineers (“Board”), and 

files this Unopposed Motion for Extension of Time to File Appellee’s Brief and 

would show as follows: 

I. INTRODUCTION 

There is no specific deadline to file this motion to extend time. See Tex. R. 

App. Proc. 38.6(d). The Appellant is unopposed to this Motion. Appellee’s current 

deadline to file its brief is April 6, 2015. 

ACCEPTED

03-14-00552-CV

4713476

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/31/2015 2:53:01 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/31/2015 2:53:01 PM JEFFREY D. KYLE Clerk
Page 2 of 4

II. ARGUMENT AND AUTHORITY

The Court may grant an extension of time under the authority of Texas Rule of 

Appellate Procedure 38.6(d). Appellee’s Brief is currently due on April 6, 2015. 

Appellee requests a thirty (30) day extension of time to May 6, 2015 to file its Brief. 

No extension has been requested or granted previously.

The Appellee needs additional time to file its Brief in order to properly and 

more completely research the record and law on the issues of this appeal and has been 

hampered in this preparation by the undersigned counsel’s current litigation schedule. 

At this time, counsel is completing a reply brief and preparing for oral arguments in 

the matter Los Fresnos Consolidated Independent School District and Michael L. 

Williams, Commissioner of Education v. Jorge Vazquez, Appeal Number 03-14-

00629-CV. Additionally, counsel has also been involved with briefing in the matter 

Antoine Dental Center v. Texas Health and Human Services Commission, D-1-GN14-2229, in the 200th District Court, Travis County, Texas. Because of these 

circumstances, the undersigned counsel respectfully requests the Court grant the 

thirty (30) day extension to file the Brief. As stated above, Appellant does not oppose 

this Motion.

III. CERTIFICATE OF CONFERENCE

The undersigned counsel hereby certifies, pursuant to Texas Rule of Appellate 

Procedure 10.1(a)(5), that on March 26, 2015, on behalf of the Board, Jennifer 
Page 3 of 4

Hopgood, the undersigned communicated with Mr. Jimmy Allen Hall, counsel for 

Appellant, Raghunath Dass. Mr. Hall responded on behalf of Appellant that he does 

not oppose Appellee’s request for a thirty (30) day extension of time for filing the 

Appellee’s brief.

IV. PRAYER

WHEREFORE, PREMISES CONSIDERED, the Board respectfully requests 

that its Unopposed Joint Motion for a thirty (30) day extension of time in which to 

file its Brief be granted and be allowed to file its Appellee’s Brief on or before May

6, 2015.

Respectfully submitted,

KEN PAXTON

Attorney General of Texas

CHARLES E. ROY

First Assistant Attorney General

JAMES E. DAVIS

Deputy Attorney General for Civil Litigation 

DAVID A. TALBOT, JR.

Chief, Administrative Law Division

/s/Jennifer L. Hopgood

Jennifer L. Hopgood

Assistant Attorney General

State Bar No. 24073010

OFFICE OF THE ATTORNEY GENERAL OF 

TEXAS

Administrative Law Division
Page 4 of 4

P.O. Box 12548, Capitol Station

Austin, Texas 78711-2548

Telephone: (512) 936-1660

Facsimile: (512) 320-0167

jennifer.hopgood@texasattorneygeneral.gov

ATTORNEY FOR APPELLEE,

TEXAS BOARD OF PROFESSIONAL

ENGINEERS

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and forgoing 

document has been served by electronic mail on this date, the 31st day of March 

2015, on the following:

Jimmy Alan Hall

JIMMY ALAN HALL, P.L.L.C.

4600 Mueller Boulevard, Suite 2121

Austin, TX 78723-3372

Facsimile: (512) 857-9195

jahall@fbjah.com

J. Woodfin Jones

ALEXANDER DUBOSE JEFFERSON

& TOWNSEND LLP

515 Congress Avenue, Suite 2350

Austin, Texas 78701-3562

Facsimile: (512) 482-9303

wjones@adjtlaw.com

Counsel for Appellee

/s/Jennifer L. Hopgood

JENNIFER L. HOPGOOD

Assistant Attorney General