Chris Bell v. Republican Governors Association ( 2015 )

ACCEPTED 03-15-00078-CV 5432033 THIRD COURT OF APPEALS AUSTIN, TEXAS 5/27/2015 12:24:15 PM JEFFREY D. KYLE CLERK No. 03-15-00078-CV FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE 5/27/2015 12:24:15 PM THIRD COURT OF APPEALS JEFFREY D. KYLE AUSTIN, TEXAS Clerk ____________________________________________________________ CHRIS BELL, Appellant V. REPUBLICAN GOVERNORS ASSOCIATION, Appellee _____________________________________________________________ ON APPEAL FROM THE 261ST JUDICIAL DISTRICT COURT, TRAVIS COUNTY, TEXAS ______________________________________________________________ APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF ______________________________________________________________ TO THE HONORABLE THIRD COURT OF APPEALS: Appellant, Chris Bell, files this Unopposed Motion to Extend Time to File Reply Brief and in support would respectfully show as follows: 1. Appellant’s reply brief is currently due on June 1, 2015. 2. Appellant requests an additional fourteen (14) days to file his reply brief, extending the time to June 15, 2015. 3. Appellant needs additional time to file his reply brief because the undersigned has a brief due in this Court on June 5, 2015, in Case No. 03-15- AUS-6110664-1 523389/1 00259-CV, styled Becky, Ltd. v. The City of Cedar Park, et al. In addition, the parties are engaged in settlement negotiations. 4. This request is not for purpose of delay, but so that justice may be done and this Court may be fully informed of all factual and legal information relevant to the proper disposition of this appeal. WHEREFORE, PREMISES CONSIDERED, Appellant requests that this Court grant his Motion for Extension of Time to File Reply Brief on or before June 15, 2015. Respectfully submitted, HUSCH BLACKWELL LLP By /s/ Elizabeth G. Bloch ELIZABETH G. BLOCH State Bar No. 02495500 Heidi.bloch@huschblackwell.com THOMAS H. WATKINS State Bar No. 20928000 Tom.Watkins@huschblackwell.com 111 Congress Avenue, Suite 1400 Austin, Texas 78701-4093 (512) 472-5456 (Telephone) (512) 479-1101 (Facsimile) ATTORNEYS FOR APPELLANT 2 AUS-6110664-1 523389/1 CERTIFICATE OF CONFERENCE The undersigned certifies that she has consulted with Terry Scarborough, counsel for Appellee, and he has indicated that Appellee is not opposed to this motion. /s/ Elizabeth G. Bloch ELIZABETH G. BLOCH CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the 27th day of May, 2015, via the Court’s electronic filing system and/or facsimile to the following: Terry L. Scarborough (512) 482-6891 (fax) Hance Scarborough, LLP 111 Congress Ave., Suite 500 Austin, Texas 78701 /s/ Elizabeth G. Bloch 3 AUS-6110664-1 523389/1