Integrity Global Security, LLC And Green Hills Software, Inc. v. Dell Marketing L.P., a Texas Limited Partnership, Dell Federal Systems, L.P., a Texas Limited Partnership And Dell Products, L.P., a Texas Limited Partnership ( 2017 )

ACCEPTED 03-17-00483-CV 21101006 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/5/2017 4:25 PM JEFFREY D. KYLE CLERK No. 03-17-00483-CV IN THE THIRD COURT OF APPEALS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/5/2017 4:25:08 PM INTEGRITY Global Security, LLC and Green Hills Software, Inc., JEFFREY D. KYLE Clerk Appellants, v. Dell Marketing L.P., Dell Federal Systems L.P., and Dell Products, L.P., Appellees. On Appeal from the 345th Judicial District Court, Travis County, Texas Trial Court Cause No. D-1-GN-16-000345 UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF Dale Wainwright Frank E. Merideth, Jr. State Bar No. 00000049 Admitted Pro Hac Vice wainwrightd@gtlaw.com meridethf@gtlaw.com Alan W. Hersh GREENBERG TRAURIG, LLP State Bar No. 24080944 1840 Century Park East, Suite 1900 hersha@gtlaw.com Los Angeles, California 90067 GREENBERG TRAURIG, LLP Telephone: (310) 586-7825 300 West 6th Street, Suite 2050 Facsimile: (310) 586-0275 Austin, Texas 78701 Telephone: (512) 320-7200 Facsimile: (512) 320-7210 COUNSEL FOR APPELLANTS INTEGRITY GLOBAL SECURITY, LLC AND GREEN HILLS SOFTWARE, INC. TO THE HONORABLE COURT: Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(a), Appellants INTEGRITY Global Security, LLC and Green Hills Software, Inc. (collectively “Appellants”) file this unopposed motion requesting an extension of time to file their reply brief, which is currently due on December 11, 2017. Appellants seek a thirty day extension, up to an including January 10, 2018, in which to file their reply brief. This is Appellants’ first request for an extension of this deadline. Appellees do not oppose the requested extension. Appellants request this extension to allow appellate counsel an opportunity to fully analyze and respond to the issues presented in Appellees’ response brief. The Court previously granted Appellees’ unopposed motion for a 30-day extension in which to file their Appellees’ Brief. Appellees’ Brief is nearly sixty pages long, excluding appendices, and Appellants require additional time to adequately and fully respond to the complex issues presented in this appeal. Furthermore, commitments in trial courts and other appellate deadlines—as well as personal commitments during the holiday season—facing Appellants’ counsel make additional time to adequately prepare and file Appellants’ reply necessary. Therefore, Appellants requests that the Court grant this thirty day extension in order to afford appellate counsel adequate time to thoroughly reply to the complex issues and arguments raised. 2 This extension is not sought for purposes of delay but that justice may be done. PRAYER For these reasons, Appellants INTEGRITY Global Security, LLC and Green Hills Software, Inc. pray that the Court grant Appellants’ motion for a thirty day extension of time, allowing Appellants up to and including January 10, 2017, to reply to Appellees’ Brief. Appellants also pray for such further relief to which they may be entitled. Respectfully submitted, GREENBERG TRAURIG, LLP By: /s/ Dale Wainwright By: /s/ Frank E. Merideth, Jr. Dale Wainwright Frank E. Merideth, Jr. State Bar No. 00000049 California State Bar No. 46266 wainwrightd@gtlaw.com Admitted Pro Hac Vice Alan W. Hersh 1840 Century Park East, Suite 1900 State Bar No. 24080944 Los Angeles, CA 90067-2101 hersha@gtlaw.com Telephone: (310) 586-7879 300 West 6th Street, Suite 2050 Facsimile: (310) 586-0275 Austin, Texas 78701 meridethf@gtlaw.com Telephone: (512) 320-7200 Facsimile: (512) 320-7210 Counsel for Appellants INTEGRITY Global Security, LLC and Green Hills Software, Inc. 3 CERTIFICATE OF CONFERENCE I certify that I communicated about this Unopposed Motion for Extension of Time to File Appellants’ Reply Brief with Sinead O’Carroll, counsel for Appellees, and she advised that they do not oppose the relief requested in this motion. /s/ Alan Hersh Alan Hersh CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was electronically filed with the Court and that counsel of record, who are deemed to have consented to electronic service, are being served on this 5th day of December 2017 via the court’s CM/ECF System. Beverly Reeves State Bar No. 16716500 breeves@reevesbrightwell.com Kim Brightwell State Bar No. 02992700 kbrightwell@reevesbrightwell.com Sinead O’Carroll State Bar No. 24013253 socarroll@reevesbrightwell.com REEVES & BRIGHTWELL LLP 221 W. 6th Street, Suite 1000 Austin, Texas 78701 Phone: (512) 334-4500 Facsimile: (512) 334-4492 Counsel for Defendants Dell Marketing L.P., Dell Federal Systems L.P., and Dell Products L.P. /s/ Dale Wainwright Dale Wainwright 4