The opinion
ACCEPTED
03-14-00552-CV
3942387
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/29/2015 9:23:05 AM
JEFFREY D. KYLE
CLERK
No. 03-14-00552-CV
RAGHUNATH DASS, P. E., IN THE THIRD
Appellant, FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
v. COURT OF APPEALS
1/29/2015 9:23:05 AM
TEXAS BOARD OF JEFFREY D. KYLE
Clerk
PROFESSIONAL ENGINEERS AUSTIN, TEXAS
Appellee.
APPELLANT’S AMENDED 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
4. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the
time to file a brief.
5. Appellant’s brief is due on January 30, 2015.
6. Appellant requests an additional 18 days to file his brief, extending the time until February
17, 2015.
7. Two previous extensions has been granted to extend the time to file Appellant’s brief.
8. 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.
APPELLANT’S THIRD UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3
C. CONCLUSION
9. 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
10. 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
APPELLANT’S THIRD UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 2 of 3
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 29th 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
APPELLANT’S THIRD UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3