Alphonso Crutch Life Support Center v. Michael L. Williams, Commissioner of Education Holland Timmons, Designee of the Commissioner And the Texas Education Agency

Opinion

ACCEPTED 03-13-00789-CV 8177126 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/10/2015 11:50:41 AM JEFFREY D. KYLE CLERK No. 03-13-00789-CV IN THE COURT OF APPEALS FOR THE THIRD DISTRICT OF TEXAS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/10/2015 11:50:41 AM ALPHONSO CRUTCH LIFE SUPPORT CENTER,JEFFREY INC., D. KYLE Appellant , Clerk

v.

MICHAEL L. WILLIAMS, COMMISSIONER OF EDUCATION; HOLLAND TIMMINS, DESIGNEE OF THE COMMISSIONER; AND THE TEXAS EDUCATION AGENCY,

Appellees.

From the 261st Judicial District Court of

Travis County, Texas

APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE MOTION FOR REHEARING

Appellant Alphonso Crutch Life Support Center, Inc. asks the court to extend

the time to file its Motion for Rehearing.

A. Introduction

1. Appellant is Alphonso Crutch Life Support Center

2. Appellant Michael L. Williams, et. al.

3. The deadline to file this response is December 15, 2015

4. The parties have agreed to this motion.

B. Argument and Authorities

5. The Court has authority under TRAP 49.8 and 10.5 to extend the time to file a Motion for Rehearing.

6. Parties have agreed to a 30 day extension to January 15th, 2016 to file

the Motion for Rehearing.

7. No extension has been granted before to file the Motion for Rehearing.

8. Appellant needs additional time because of a very busy litigation

schedule, the complicated issues contemplated in the Motion for Rehearing and the

upcoming Holiday period.

C. Conclusion/Prayer

9. For these reasons, Appellant asks the Court to grant an extension of time

to file its brief until January 15, 2016.

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 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 9th day of December 2015.

Beth Klusmann Assistant Solicitor General bethklusmann@texasattorneygeneral.com (512) 936-1914

/s/ Gary L. Bledsoe Gary Bledsoe