FILED

15-0139
3/2/2015 3:37:00 PM
tex-4336999
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK

NO. 15-0139
In the
Supreme Court of Texas
_______________________________________
IN RE STATE OF TEXAS,

Relator.
_______________________________________
On Petition for Writ of Mandamus
167th Judicial District Court, Travis County, Texas
_______________________________________
REAL PARTIES IN INTERESTS UNOPPOSED MOTION
TO EXTEND TIME TO FILE RESPONSE TO PETITION FOR WRIT OF MANDAMUS
________________________________________
TO THE HONORABLE TEXAS SUPREME COURT:
Real Parties in Interest, Suzanne Bryant and Sarah Goodfriend, file this
unopposed motion and ask the Court for a thirty (30) day extension of time by which
to file their response to the petition for writ of mandamus. TEX. R. APP. P. 10.5(b);
TEX. R. APP. P. 53.7. The petition for mandamus was recently filed in this case on
February 20, 2015, and the current deadline for the response is March 12, 2015.
Granting this motion for extension of time would make the response due by Monday,
April 13, 2015.
Real Parties in Interest recently retained the undersigned appellate counsel Kurt
Kuhn to represent them in this mandamus proceeding in the Texas Supreme Court,

and Mr. Kuhn has not previously been involved in the underlying matter. Mr. Kuhn
is primarily responsible for drafting and filing the response and needs additional time
to familiarize himself with the record in this case and the relevant law in order to
properly prepare the response. Relators counsel has also informed Mr. Kuhn that
Relator intends to file an amended mandamus petition in this proceeding, and the
extension of time is necessary to allow proper review of any changes that Relator
intends to make. Real Parties in Interests counsel has several other deadlines and
commitments which necessitate the filing of this motion, including preparing the
requested response in the companion mandamus proceeding, In re State of Texas, No.
15-0135.
This request is not made for the purpose of delay, but is necessary in order to
allow Real Parties in Interests counsel time to properly prepare the response.
Opposing counsel has been conferred with and has indicated that they do not oppose
the granting of this motion. This is the first request for extension of time requested
for the response. Neither the Parties nor the Court will be prejudiced by the granting
of this motion.
For these reasons, Real Parties in Interest, Suzanne Bryant and Sarah
Goodfriend, ask the Court to grant a thirty (30) day extension of time by which to file
their response to the petition for writ of mandamus, making the response due on
April 13, 2015.

Dated: March 2, 2015

Respectfully submitted,

Charles Herring, Jr.

State Bar No. 09534100
Jess M. Irwin III
State Bar No. 10425700
HERRING & IRWIN, L.L.P.
1411 West Avenue, Suite 100
Austin, Texas 78701
(512) 320-0665
(512) 519-7580 (fax)
cherring@herring-irwin.com
jess@herring-irwin.comn

/s/Kurt Kuhn
Kurt Kuhn
State Bar No. 24002433
Lisa Bowlin Hobbs
State Bar No. 24026905
KUHN HOBBS PLLC
3307 Northland Drive, Suite 310
Austin, Texas 78731
(512) 476-6003
(512) 476-6002 (fax)
Lisa@KuhnHobbs.com
Kurt@KuhnHobbs.com

Catherine A. Mauzy
State Bar No. 13239400
MAUZY & TUCKER PLLC
1717 West 6th Street, Suite 315
Austin, Texas 78701
(512) 474-1493
(512) 479-7910 (fax)
cam@mauzylaw.com

Brian Thompson
State Bar No. 24051425
HOPPER MIKESKA, PLLC
400 West 15th Street, Suite 408
Austin, Texas 78701
(512) 615-6195
(512) 610-1306 (fax)
bthompson@hoppermikeska.com

COUNSEL FOR REAL PARTIES IN INTEREST

CERTIFICATE OF CONFERENCE
Pursuant to Texas Rule of Appellate Procedure 10.1, I hereby certify that I
conferred with counsel for Relator regarding this motion, and he indicated that he
does not oppose the granting of this motion.

/s/ Kurt Kuhn

Kurt Kuhn

CERTIFICATE OF SERVICE
I hereby certify that I served a copy of this motion on counsel of record
electronically, in accordance with the Texas Supreme Courts rules on electronic filing
on March 2, 2015, as listed below:
/s/ Kurt Kuhn
Kurt Kuhn

Michael P. Murphy
Assistant Solicitor General
OFFICE OF THE ATTORNEY GENERAL
P.O. Box 12548 (MC 059)
Austin, Texas 78711-2548

Counsel for Relator, State of Texas

via e-Service