Raghunath Dass, P.E. v. Texas Board of Professional Engineers

Court of Appeals of Texas

Raghunath Dass, P.E. v. Texas Board of Professional Engineers

DecidedJanuary 9, 2015

Docket03-14-00552-CV

StatusPublished

This text of Raghunath Dass, P.E. v. Texas Board of Professional Engineers (Raghunath Dass, P.E. v. Texas Board of Professional Engineers) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Raghunath Dass, P.E. v. Texas Board of Professional Engineers, (Tex. Ct. App. 2015).

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Opinion

ACCEPTED 03-14-00552-CV 3709964 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/9/2015 10:52:36 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 1/9/2015 10:52:36 AM TEXAS BOARD OF JEFFREY D. KYLE Clerk PROFESSIONAL ENGINEERS AUSTIN, TEXAS Appellee.

APPELLANT’S AMENDED SECOND 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, 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 16, 2015. 6. Appellant requests an additional 14 days to file his brief, extending the time until January 30, 2015. 7. One previous extension 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 for several days. 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.

APPELLANT’S AMENDED SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3 D. PRAYER 10. For these reasons, Appellant asks the Court to grant an extension of time to file his brief until January 30, 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 AMENDED SECOND 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 Amended Second Unopposed Motion to Extend Time to File Brief has been sent in accordance with the Texas Rules of Appellate Procedure, as noted below, on this 9th 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 G Hand Delivery in Person or by Agent G Courier Receipted Delivery G Telephonic Document Transfer O eService

APPELLANT’S AMENDED SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3

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ACCEPTED 03-14-00552-CV 3709964 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/9/2015 10:52:36 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 1/9/2015 10:52:36 AM TEXAS BOARD OF JEFFREY D. KYLE Clerk PROFESSIONAL ENGINEERS AUSTIN, TEXAS Appellee.

APPELLANT’S AMENDED SECOND 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, 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 16, 2015. 6. Appellant requests an additional 14 days to file his brief, extending the time until January 30, 2015. 7. One previous extension 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 for several days. 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.

APPELLANT’S AMENDED SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3 D. PRAYER 10. For these reasons, Appellant asks the Court to grant an extension of time to file his brief until January 30, 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 AMENDED SECOND 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 Amended Second Unopposed Motion to Extend Time to File Brief has been sent in accordance with the Texas Rules of Appellate Procedure, as noted below, on this 9th 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 G Hand Delivery in Person or by Agent G Courier Receipted Delivery G Telephonic Document Transfer O eService

APPELLANT’S AMENDED SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3

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Raghunath Dass, P.E. v. Texas Board of Professional Engineers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/raghunath-dass-pe-v-texas-board-of-professional-engineers-texapp-2015.