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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 

THE CITY OF WILLOW PARK’S MOTION TO EXTEND 

TIME TO FILE MOTION FOR REHEARING 

TO THE HONORABLE THIRD COURT OF APPEALS: 

Appellee, City of Willow Park (“Willow Park”), files this, its Motion for an 

Extension of Time to File a Motion for Rehearing in the above-referenced cause, and would 

show as follows: 

Willow Park’s Motion for Rehearing is currently due July 23, 2015. Willow Park

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

deadline. This is Willow Park’s first request for an extension of time to file a motion for 

rehearing. 

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

Commission on Environmental Quality (“TCEQ”) are UNOPPOSED to this request for an 

extension of time. 

ACCEPTED

03-13-00113-CV

6044095

THIRD COURT OF APPEALS

AUSTIN, TEXAS

7/13/2015 4:03:00 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/13/2015 4:03:00 PM JEFFREY D. KYLE Clerk
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REASONS FOR REQUEST

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

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

responsible for preparing this Motion, Mary K. Sahs, will not be able to begin preparations 

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 Willow Park was 

on vacation out of state until July 13, 2015.

2. The first meeting of the Willow Park City Council after issuance of the opinion will 

be on July 14, at which time it will consider the Court’s opinion.

3. Ms. Sahs will be on vacation July 20 – 26, 2015.
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CONCLUSION AND PRAYER

For the foregoing reasons, Willow Park respectfully requests an additional 43 days, 

up to and including September 4, 2015, to file its Motion for Rehearing. This is Willow 

Park’s first request for an extension of time to file this Motion.

Respectfully Submitted,

/s/ Mary K. Sahs

Mary K. Sahs

State Bar No. 17522300

MARY K. SAHS, P.C.

609 Thrasher Lane

Austin, TX 78741

(512) 326-2556 (telephone)

(512) 597-2516 (facsimile)

COUNSEL FOR CITY OF WILLOW 

PARK

CERTIFICATE OF CONFERENCE

By my signature below, I hereby certify that counsel for the City of Willow Park conferred 

with Eric Allmon, counsel for the City of Aledo, Ms. Nancy Olinger, counsel for the TCEQ, 

and Mr. Brent Ryan, counsel for Republic. Mr. Allmon, Ms. Olinger, and Mr. Ryan are

UNOPPOSED to this motion.
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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/ Mary K. Sahs

Mary K. Sahs

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 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

FOR THE CITY OFALEDO:

Mr. Eric Allmon

Frederick, Perales, Allmon & Rockwell, P.C.

707 Rio Grande, Suite 200

Austin, Texas 78701 

Telephone (512) 469-6000 

Facsimile (512) 482-9346

ealmon@lf-lawfirm.com