Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/17/2015 3:58:09 PM JEFFREY D. KYLE Clerk NO. 03-15-00349-CV THIRD COURT OF APPEALS 11/17/2015 3:58:09 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00349-CV *1 ACCEPTED [7871147] CLERK In the Third Court of Appeals Of Texas SHAMROCK PSYCHIATRIC, P.A.
Appellants , V .
TEXAS HEALTH AND HUMAN SERVICES COMMISSION,
KYLE JANEK, MD, E XECUTIVE C OMM ’ R
AND DOUGLAS WILSON, I NSPECTOR G ENERAL
Appellees, On appeal from the 126 District Court, Travis County, Texas
Cause NO. D-1-GV-14-001833 FIRST UNOPPOSED MOTION TO
EXTEND TIME TO FILE REPLY BRIEF
Appellant asks the Court to extend the time to file Appellant’s Reply Brief for
an extension of 20 days.
A. Introduction 1. Appellant is Shamrock Psychiatric, P.A.
2. This motion is filed within the period to file a motion to extend the time to
file briefs, as required by Rules 10.5 and 38.6.
3. The Appellees are not opposed to this motion.
B. Argument & Authorities 4. The Court may grant an extension of time to file briefs under Texas Rule of
Appellate Procedure 38.6.
5. The deadline to file the Reply Brief is November 19, 2015.
6. Appellant requests this extension due to counsel having:
- Intervening cases that had immediate impending deadlines preventing a
timely reply brief to be completed;
- A week-long out-of-state administrative law conference that occurred in
the past month;
- Unexpected contract negotiations required in a separate matter that
distracted the undersigned counsel from reviewing and addressing Appellee’s
brief for over a week.
7. No previous extension has been requested or granted to extend the time to
file Appellant’s Brief.
C. Prayer 8. For these reasons, Appellant asks the Court to grant an extension of time to
file Brief until December 9, 2015. *3 Respectfully Submitted, ___________________________ Jason Ray State Bar No. 24000511 RIGGS & RAY, P.C.
506 West 14 Street Austin, Texas 78701 (512) 457-9806 Telephone (512) 457-9066 Facsimile jray@r-alaw.com ATTORNEY FOR APPELLANT CERTIFICATE OF CONFERENCE
I communicated by email on November 17, 2015 with opposing counsel,
Eugene A. Clayborn and he advised that he does not oppose this motion.
___________________________ Jason Ray CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was
served by eservice on November 17, 2015 to the following:
Eugene A. Clayborn
Assistant Attorney General
Deputy Chief, Administrative Law Division
Office of the Attorney General of Texas
P.O. Box 125548, Capitol Station
Austin, Texas 78711-2548
Eugene.clayborn@texasattorneygeneral.gov
___________________________ Jason Ray