Raghunath Dass, P.E. v. Texas Board of Professional Engineers

Case Information

No. 03-14-00552-CV

| RAGHUNATH DASS, P. E., Appellant, | $\leftarrow$ | IN THE THIRD | | :--: | :--: | :--: | | | $\leftarrow$ | FILED IN | | | $\leftarrow$ | 3rd COURT OF APPEALS | | v. | $\leftarrow$ | AUSTIN, TEXAS | | | $\leftarrow$ | 1/29/2015 9:23:05 AM | | TEXAS BOARD OF | $\leftarrow$ | JEFFREY D. KYLE | | PROFESSIONAL ENGINEERS | $\leftarrow$ | Cierk | | Appellee. | $\leftarrow$ | AUSTIN, TEXAS |

APPELLANT'S THIRD UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF

Appellant asks the Court to extend the time to file his brief.

A. INTRODUCTION

1. Appellant is Raghunath Dass, Ph.D., P.E.; Appellee is the Texas Board of Professional Engineers.
2. There is no specific deadline to file this motion to extend time. See Tex. R. App. P. 38.6(d).
3. Appellant's counsel has conferred with Appellee's counsel, who stated that she is unopposed to this motion and the proposed new time to file brief for Appellant.

B. ARGUMENT &; AUTHORITIES

1. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time to file a brief.
2. Appellant's brief is due on January 30, 2015.
3. Appellant requests an additional 18 days to file his brief, extending the time until February 17, 2015.
4. Two previous extensions has been granted to extend the time to file Appellant's brief.
5. Appellant needs additional time to file his brief because appellant's attorney has been ill and still recovering, because of unresolved confusion regarding the District Clerk's filing a supplemental record as a result of the District Court's approval of Appellant's/Plaintiff's Second Amended Formal Bill of Exception, and because of the convergence of deadlines upon appellant's attorney for January 30 - 31, 2015, of which he was unaware when he sought the prior extension to January 30, 2015.

C. CONCLUSION

1. Appellant is requesting an extension of time to file his brief so that appellant's attorney has sufficient to time to prepare his brief in a competent and clear manner.

D. PRAYER

1. For these reasons, Appellant asks the Court to grant an extension of time to file his brief until February 17, 2015.

Respectfully submitted, JIMMY Alan Hall, PLLC 4600 Mueller Boulevard, Suite 2121 Austin, Texas 78723-3372 Telephone: 512-722-3190 Telecopier: 512-857-9195 jahall@fbjah.com

State Bar No. 08759800 ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant's Third Unopposed Motion to Extend Time to File Brief has been sent in accordance with the Texas Rules of Appellate Procedure by electronic service on this ${29}^{\text{th}}$ day of January, 2015, to:

Jennifer L. Hopgood
Assistant Attorney General
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 936-1660
Facsimile: (512) 320-0167
jennifer.hopgood@texasattorneygeneral.gov

Case Details

Case Name: Raghunath Dass, P.E. v. Texas Board of Professional Engineers

Court Name: Court of Appeals of Texas

Date Published: Jan 29, 2015

Docket Number: 03-14-00552-CV

Court Abbreviation: Tex. App.