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 ( “B oard”) , 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

CLERKPage 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 request s a thirty (3 0) day extension of time to Ma y 6 , 2015 to file its Brief

. No extension has been requested or granted previously. The Appellee need s 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 li tigation schedule. At this time, counsel is completing a reply brief and preparing for oral arguments in
the matter Los Fresnos Consolidated Indep endent Sch ool Dist rict and Michael L. Williams, Commissioner of Education v. Jorge Vazquez , Appeal Number 03

- 14

- 00629

- CV

. Additionally, counsel has also been involved with briefing i n the matter
Antoine Dental Center v. Texas Healt h and Human Services Commissio n , D

- 1

- GN

14

- 2229 , in the 200 th District Court , Travis C ounty, Texas

. Because of these circumstances, the undersigned counsel respectfully request s the Court grant the thirty (3 0) day extension to file the Brief. As stated above, Appellant do es 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 , 201 5 , on behalf of the Board , JenniferPage 3 of 4

Hopgood , the undersigned communicated with Mr. J immy Allen Hall, counsel for Appellant , Raghunath Dass. Mr. Hall r esponded on beha lf of Appellant that he does not oppose Appellee ’s request for a thirty (3 0) day extension of time for filing the Appellee ’ s brief.
IV. PRAYER WHEREFORE, PREMISES CONSIDERED, the Board respectfully request s that its Unopp osed Joint Motion for a thirty (3 0) day extensio n of time in which to
file its Brief be granted a nd 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 O FFICE OF THE A TTORNEY G ENERAL OF T EXAS Administrative Law DivisionPage 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 J IMMY A LAN H ALL , P.L.L.C. 4600 Mueller Boulevard, Suite 2121 Austin, TX 78723

- 3372 Facsimile: (512) 857

- 9195 jahall@fbjah.com
J. Woodfin Jones A LEXANDER D UBOSE J EFFERSON & T OWNSEND 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