Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/5/2017 4:25:08 PM JEFFREY D. KYLE Clerk o . 03-17-00483-CV N THIRD COURT OF APPEALS JEFFREY D. KYLE 12/5/2017 4:25 PM AUSTIN, TEXAS 03-17-00483-CV *1 ACCEPTED [21101006] CLERK IN THE THIRD COURT OF APPEALS INTEGRITY Global Security, LLC and Green Hills Software, Inc., 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 G REENBERG T RAURIG , LLP 1840 Century Park East, Suite 1900
hersha@gtlaw.com Los Angeles, California 90067
G REENBERG T RAURIG , Telephone: (310) 586-7825
300 West 6 th Street, Suite 2050 Facsimile: (310) 586-0275
Austin, Texas 78701
Telephone: (512) 320-7200
Facsimile: (512) 320-7210
C OUNSEL FOR A PPELLANTS INTEGRITY G LOBAL S ECURITY , LLC AND G REEN
H ILLS S OFTWARE , I NC .
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.
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, G REENBERG T RAURIG , 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 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. *4 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 5 th 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
socarroll@reevesbrightwell.com
R EEVES & B RIGHTWELL
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
