Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/25/2015 2:50:44 PM JEFFREY D. KYLE Clerk No. 03-15-00509-CV THIRD COURT OF APPEALS 11/25/2015 2:50:44 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00509-CV *1 ACCEPTED [7995768] CLERK IN THE COURT OF APPEALS
FOR THE THIRD DISTRICT OF TEXAS ALPHONSO CRUTCH LIFE SUPPORT CENTER, INC.,
Appellant , v.
MICHAEL L. WILLIAMS, COMMISSIONER OF EDUCATION;
HOLLAND TIMMINS, DESIGNEE OF THE COMMISSIONER; AND
THE TEXAS EDUCATION AGENCY,
Appellees. From the 353 rd Judicial District Court of
Travis County, Texas APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE
BRIEF
Appellant Alphonso Crutch Life Support Center, Inc. asks the court to extend
the time to file its brief.
A. Introduction 1. Appellant is Alphonso Crutch Life Support Center
2. Appellee is Michael L. Williams, et. al.
3. The deadline to file this response is December 9, 2015
4. The motion is unopposed.
B. Argument and Authorities
5. The Court has authority under TRAP 38.6 and 10.5 to extend the time
to file the brief.
6. Appellant seeks an extension to January 11 th , 2016 to file the brief and
the appellee does not oppose.
7. No extension has been granted before to extend the time to file
Appellant’s brief.
8. Appellant needs additional time because of an extreme busy schedule,
including the following: the week of November 9 th taking depositions for a
December arbitration; the week of November 16 th serving as lead counsel in a 5 day
trial; the week of November 23 rd preparing pretrial disclosures for an upcoming
arbitration and objections to witnesses and exhibits; and the undersigned counsel has
two Arbitrations scheduled in early December. One is scheduled December 1-3 and
the other December 7-11. Counsel has a deposition in another case set the next week
and then the Holidays begin.
C. Conclusion/Prayer 9. For these reasons Appellant asks the Court to grant an extension of time
to file its brief until January 11, 2015.
Respectfully submitted, THE BLEDSOE LAW FIRM, PLLC By: /s/ Gary L. Bledsoe Gary L. Bledsoe State Bar No. 02476500 garybledsoe@sbcglobal.net Alondra Johnson ajohnson@thebledsoelawfirm.com State Bar No. 24087801 316 W. 12th Street Austin, Texas 78701 (512) 322-9992 Telephone (512) 322-0840 Fax *4 CERTIFICATE OF CONFERENCE
I certify that I have conferred with Beth Klusmann by telephone and e-mail
and she has agreed and is unopposed to Appellant’s Motion to Extend Time.
/s/ Gary L. Bledsoe Gary Bledsoe CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has
been forwarded to the following parties via e-mail/e-service, United States certified
mail and/or via facsimile on this 25th day of November 2015.
Beth Klusmann
Assistant Solicitor General
bethklusmann@texasattorneygeneral.com
(512) 936-1914
/s/ Gary L. Bledsoe Gary Bledsoe