FILED 14-1010 1/7/2015 5:32:53 PM tex-3689270 SUPREME COURT OF TEXAS BLAKE A. HAWTHORNE, CLERK NO. 14-1010

IN THE SUPREME COURT OF TEXAS

CRYSTAL CLEAR WATER SUPPLY CORPORATION Petitioner, vs. TEXAS GENERAL LAND OFFICE AND TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Respondents.

Petitioner’s Unopposed Second Motion for Extension of Time to File Petition for Review

TO THE HONORABLE SUPREME COURT OF TEXAS: Petitioner Crystal Clear Water Supply Corporation (“Crystal Clear”) files this Unopposed Second Motion for Extension of Time to File Petition for Review pursuant to Texas Rules of Appellate Procedure 53.7(f) and 10.5(b) and in support thereof would respectfully show the Court as follows: 1. Crystal Clear is the Petitioner. Texas General Land Office (“GLO”) and Texas Commission on Environmental Quality (“TCEQ”) are the Respondents.

2. This case is on appeal from the Third Court of Appeals in Austin, Texas.

The style and number of the case in the Court of Appeals was: Court of Appeals Number: 03-13-00528-CV; Trial Court Case Number: D-1-GN-12-000305; Texas General Land Office and Texas Commission on Environmental Quality, Appellants/ Cross-Appellees vs. Crystal Clear Water Supply Corporation, Appellee/ Cross-Appellant 3. The Court of Appeals issued its opinion on August 22, 2014 and ruled on Crystal Clear’s timely filed Motion for Rehearing and Motion for Rehearing En Banc on October 28, 2014.

4. Pursuant to Tex. R. App. P. 10.5(b) and 53.7(f), the Court may extend the time for a party to file a petition for review.

5. Crystal Clear’s present deadline for filing its petition for review is January 9, 2014. The deadline for filing a motion to extend the deadline for filing Crystal Clear’s petition for review is January 24, 2015. This motion to extend the deadline for filing Crystal Clear’s petition for review is filed within both the deadline for filing the petition for review and the deadline for filing a motion to extend time for filing the petition for review.

6. Crystal Clear respectfully requests an additional fourteen days to file its petition for review, extending the time for that filing to January 23, 2015.

7. This is Crystal Clear’s second request for an extension of time in which to file its petition for review. This request is unopposed by the parties to the case.

8. The facts relied upon by Crystal Clear to explain its need for an extension of time in which to file its petition for review are as follows: This is a complex case involving extensive briefing at the Court of Appeals.

In order to properly prepare the petition for review in this matter, Crystal Clear respectfully requests an additional fourteen days in which to submit that petition for review.

9. For the above and foregoing reasons, Crystal Clear respectfully requests a fourteen (14) day extension of time, extending Crystal Clear’s deadline for filing a petition for review until January 23, 2015.

10. This motion is not sought for purposes of delay, but rather, so that justice may be done.

WHEREFORE, PREMISES CONSIDERED, Petitioner Crystal Clear respectfully requests and prays that this Court extend the filing time for the Petitioner’s petition for review by granting an extension of fourteen (14) days and fix such date of filing on the 23rd day of January, 2015.

Respectfully submitted, THE TERRILL FIRM, P.C.

By: /s/ Scott R. Shoemaker______________ Paul M. Terrill III State Bar No. 00785094 Scott R. Shoemaker State Bar No. 24046836 W. 10th St. Austin, Texas 78701 (512) 474-9100 (512) 474-9888 (fax) [email protected] [email protected] G. Alan Waldrop State Bar No. 20685700 The Waldrop Firm West 10th Street Austin, Texas 78701 (512) 982-9950 (512) 474-9888 (fax) [email protected] ATTORNEYS FOR PETITIONER

CERTIFICATE OF CONFERENCE Pursuant to Texas Rule of Appellate Procedure 10.1, counsel for Crystal Clear, Scott Shoemaker, conferred with Mark Walters, counsel for TCEQ, and Broadus Spivey and Ken Ramirez, counsel for GLO. Counsel advised that this motion was unopposed.

/s/ Scott R. Shoemaker______________ Scott R. Shoemaker CERTIFICATE OF SERVICE I hereby CERTIFY that on January 7, 2015, a true and complete copy of the above was sent to the counsel of record via e-service or other electronic means: Ken Ramirez Courtesy Copy sent via first-class mail LAW OFFICES OF KEN RAMIREZ Congress Avenue, Ste 400 Austin, TX 78701 Broadus A. Spivey LAW OFFICES OF BROADUS A SPIVEY, PC East Avenue Austin, TX 78701 ATTORNEYS FOR TEXAS GENERAL LAND OFFICE Mark Walters Priscilla Hubenak Assistant Attorney General Environmental Protection and Admin. Law Division MC-018-1 P.O. Box 12548 Austin, TX 78711-2548 ATTORNEYS FOR TCEQ /s/ Scott R. Shoemaker Scott R. Shoemaker