Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney General of the State of Texas v. CGG Veritas Services (U.S.), Inc.

• Court: Court of Appeals of Texas
• Decided: February 9, 2015
• Docket: 03-14-00713-CV
• Status: Published

Opinion

ACCEPTED 03-14-00713-CV 4081063 THIRD COURT OF APPEALS AUSTIN, TEXAS 2/9/2015 5:06:23 PM JEFFREY D. KYLE CLERK No. 03-14-00713-CV

In The Court of Appeals 3rd COURTFILED IN OF APPEALS AUSTIN, TEXAS For the Third Judicial District 2/9/2015 5:06:23 PM JEFFREY D. KYLE Austin, Texas Clerk

SUSAN COMBS, COMPTROLLER OF PUBLIC ACCOUNTS OF THE STATE OF TEXAS, AND GREG ABBOTT, ATTORNEY GENERAL OF THE STATE OF TEXAS, Appellants, v. CGG VERITAS SERVICES (U.S.), INC., Appellee.

On Appeal from the 353rd Judicial District Court of Travis County, Texas

APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME

TO THE HONORABLE THIRD COURT OF APPEALS:

In accordance with Texas Rules of Appellate Procedure 10.5(b) and 38.6(d),

Appellants Susan Combs, Comptroller of Public Accounts of the State of Texas, and

Ken Paxton, Attorney General of the State of Texas, move for an extension of time

to file its brief. Appellees do not oppose motion.

I.

Appellants’ brief is currently due on February 12, 2015. Appellants seek a 30-

day extension, which would make its brief due on or before Monday, March 16, 2015.

No previous extensions have been requested. First, Appellants are represented by new lead counsel in this Court. Appellants’

new counsel on appeal requires time to review the record and research the legal issues

prior to preparing and filing the petition for review.

Second, Appellants’ new lead counsel has and will continue to have a

significant workload in other matters that will make it impossible to complete by the

current deadline a response to the petition that will be helpful to the Court. That

workload includes reviewing the record and

• drafting a petition for review in Texas Health and Human Services

Commission and Officer of the Inspector General v. Harlingen Family Dentistry,

P.C., No. -------, in the Texas Supreme Court

• drafting a motion to affirm in response to a statement of jurisdiction in

Evenewel v. Abbott, No. 14-940, in the U.S. Supreme Court, and

• ongoing responsibilities in Escamilla v. Stephens, No. 12-70029, a capital

habeas case in the U.S. Court of Appeals for the Fifth Circuit.

II.

For each of these reasons, counsel for the Appellants requests additional time

to review the record on appeal and analyze the relevant law so as to provide the Court

with a thorough and helpful brief.

PRAYER

Appellants respectfully requests that the Court grant it a 30-day extension of

time to file its brief, making that brief due on March 16, 2015.

2 Respectfully submitted.

KEN PAXTON Attorney General of Texas

CHARLES E. ROY First Assistant Attorney General

SCOTT A. KELLER Solicitor General

/s/ April L. Farris APRIL L. FARRIS Assistant Solicitor General State Bar No. 24069702

OFFICE OF THE ATTORNEY GENERAL P.O. Box 12548 (MC 059) Austin, Texas 78711-2548 Tel.: (512) 936-2923 Fax: (512) 474-2697 april.farris@texasattorneygeneral.gov

COUNSEL FOR APPELLANTS

3 CERTIFICATE OF CONFERENCE

I hereby certify that on February 6, 2015 I contacted counsel for Appellees

Counsel does not oppose this motion.

/s/ April L. Farris April L. Farris

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has

been electronically filed and served via File&ServeXpress on February 9, 2015, to the

following:

Amanda Taylor State Bar No. 24045921 James F. Martens State Bar No. 13050720 Lacy Leonard State Bar No. 24040561 MARTENS TODD LEONARD & TAYLOR 301 Congress Ave., Suite 1950 Austin, Texas 78701 Tel.: (512) 542-9898 Fax: (512) 542-9899 ataylor@textaxlaw.com jmartens@textaxlaw.com lleonard@textaxlaw.com

Counsel for Appellee