NO. 03-13-00113-CV 

TEXAS COMMISSION ON 

ENVIRONTMENTAL QUALITY AND 

REPUBLIC WASTE SERVICES, LTD. 

Appellants

v. 

THE CITY OF ALEDO AND THE CITY 

OF WILLOW PARK, 

Appellees

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IN THE COURT OF APPEALS 

FOR THE THIRD JUDICIAL 

DISTRICT OF TEXAS 

MOTION TO EXTEND 

TIME TO FILE MOTION FOR REHEARING 

TO THE HONORABLE THIRD COURT OF APPEALS: 

Appellee City of Aledo (“Aledo”) files this, its Motion for an Extension of Time 

to File a Motion for Rehearing in the above-referenced cause. For support, Aledo 

respectfully offers the following: 

 Aledo’s Motion for Rehearing is currently due July 23, 2015. Aledo requests that 

the deadline be extended until September 4, 2015, 43 days from the current deadline. 

 Counsel for Republic Waste Services of Texas, Ltd. (“Republic”), the Texas 

Commission on Environmental Quality (“TCEQ”), and the City of Willow Park are 

UNOPPOSED to this request for an extension of time. 

REASONS FOR REQUEST 

Aledo requests an extension of time to file its Motion for Rehearing because the 

City’s management will not be able to consider the court’s opinion, and the attorney 

responsible for preparing this Motion, Eric Allmon, will not be able to begin preparations 

ACCEPTED

03-13-00113-CV

6042142

THIRD COURT OF APPEALS

AUSTIN, TEXAS

7/13/2015 3:22:16 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/13/2015 3:22:16 PM JEFFREY D. KYLE Clerk
for or complete the motion within the current deadline of July 23, 2015, despite the 

exercise of diligence: 

1. At the time of issuance of the opinion, the Mayor of the City of Aledo was on 

vacation, lasting until July 13, 2015. 

2. The first meeting of the Aledo City Council after issuance of the opinion will be 

on July 23, at which time it will consider the Court’s opinion. 

3. Mr. Allmon is preparing prefiled testimony in the Matter of the Application for 

Creation of Travis County Municipal Utility District No. 22, due July 17, 2015 

(State Office of Administrative Hearings Docket No. 582-15-2392). 

4. Mr. Allmon will be on vacation August 7 – 16, 2015. 

CONCLUSION AND PRAYER 

 For the foregoing reasons, Aledo respectfully requests an additional 43 days, up to 

and including September 4, 2015, to file its Motion for Rehearing. This is Aledo’s first 

request for an extension of time to file this Motion. 

Respectfully Submitted, 

 /s/ Eric Allmon 

Eric Allmon 

State Bar No. 24031819 

FREDERICK, PERALES, ALLMON &

ROCKWELL, P.C.

707 Rio Grande, Suite 200 

Austin, Texas 78701 

Telephone (512) 469-6000 

Facsimile (512) 482-9346 

COUNSEL FOR CITY OF ALEDO 
CERTIFICATE OF CONFERENCE 

By my signature below, I hereby certify that counsel for Aledo conferred with Ms. Nancy 

Olinger, counsel for the TCEQ, Mr. Brent Ryan, counsel for Republic, and Ms. Mary 

Sahs, counsel for the City of Willow Park. Ms. Olinger, Mr. Ryan, and Ms. Sahs are 

UNOPPOSED to this motion. 

CERTIFICATE OF SERVICE 

By my signature below, I certify that on this 13th day of July, 2015, a copy of the 

foregoing document was served upon the parties identified below via facsimile 

transmission, electronic mail, hand delivery and/or U.S. Postal Mail. 

 

 /s/ Eric Allmon 

Eric Allmon 

FOR THE TEXAS COMMISSION ON 

ENVIRONMENTAL QUALITY: 

Nancy Olinger 

Office of the Attorney General 

Envtl. Prot. & Admin. Law Div. 

P.O. Box 12548 (MC-018) 

Austin, TX 78711-2548 

Telephone (512) 463-2012 

Facsimile (512) 320-0911 

Nancy.Olinger@texasattorneygeneral.gov 

FOR THE CITY OF WILLOW PARK: 

Mary K. Sahs 

Sahs & Associates, P.C. 

609 Thrasher Ln. 

Austin, TX 78741 

Telephone (512) 326-2556 

Facsimile (512) 326-2606 

marysahs@sahslaw.onmicrosoft.com 

FOR REPUBLIC WASTE SERVICES OF 

TEXAS: 

Mr. Brent Ryan 

Mr. Paul R. Tough 

McElroy, Sullivan, Miller, 

Weber & Olmstead, L.L.P. 

P.O. Box 12127 

Austin, TX 78711 

Telephone (512) 327-8111 

Facsimile (512) 327-6566 

bryan@msmtx.com 

ptough@msmtx.com