ACCEPTED 06-15-00078-cv SIXTH COURT OF APPEALS TEXARKANA, TEXAS 11/18/2015 9:25:13 AM DEBBIE AUTREY CLERK

NO. 6-15-00078-CV ______________________________________________ FILED IN IN THE COURT OF APPEALS FOR THE 6th COURT OF APPEALS SIXTH DISTRICT OF TEXAS AT TEXARKANA TEXARKANA, TEXAS ______________________________________________ 11/18/2015 9:25:13 AM DEBBIE AUTREY TOCHRIL, INCORPORATED, Clerk Appellants,

VS.

TEXAS WORKFORCE COMMISSION, Appellee. ______________________________________________

ON APPEAL FROM 53rd JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

Appellant Tochril, Incorporated, doing business as Health Force (“Health Force”), files

this Motion For Extension of Time to File Appellant’s Brief pursuant to Rules 10.5 and

38.6(d) of the Texas Rules of Appellate Procedure.

By October 27, 2015 letter from the Court’s deputy clerk, the initial deadline for

Appellant to file its appellate brief is November 30, 2010 (the first business day after the

Thanksgiving holiday).

This is Appellants’ first request for an extension of time.

Appellant requests an extension of time until December 31, 2015 to file its brief.

This extension is sought for the following reasons:

1. Counsel for Appellant are set for an evidentiary administrative (“Rule 13”) hearing on December 1, 2015 in ExTech Consulting, LLC, Tax Account No. 14-701499-6, Case No. 15-096-6515;

Page 1 084891/000006 140 - 1819912v1 2. Counsel for Appellant are set for trial on December 9, 2015 in Civil Action No. 4:14- cv-00274; Michele Spencer vs. KS Management Services, LLC; In the United States District Court for the Southern District of Texas, Houston Division; and

3. Seven depositions are scheduled for December 7-18, 2015 in order to meet a January 4, 2016 discovery deadline in Civil Action No. 2:14-cv-00131; Zach Westbrook v. Advanced Solids Control, LLC; In the United States District Court Southern District of Texas Corpus Christi Division.

WHEREFORE, Appellant respectfully requests this Court grant its request for

extended time until December 31, 2015 to file its appellate brief.

Respectfully submitted,

CRAIN, CATON & JAMES, PC

By: s/ Juliann H. Panagos JULIANN H. PANAGOS State Bar No. 06861100 [email protected] MICHAEL D. SEALE State Bar No. 00784938 [email protected] 1401 McKinney Street, Suite 1700 Houston, Texas 77010 Telephone: 713-752-8696 Facsimile: 713-658-1921

ATTORNEYS FOR PLAINTIFF TOCHRIL, INCORPORATED

Page 2 084891/000006 140 - 1819912v1 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of Motion For Extension of Time to File Appellant’s Brief has been forwarded to the following attorney in the manner stated on the 18th day of November 2015:

VIA CERTIFIED MAIL / RETURN RECEIPT REQUESTED E-MAIL: [email protected]

Mr. Peter Laurie Assistant Attorney General Taxation Division P.O. Box 12548 Austin, Texas 78711-2548

s/ Juliann H. Panagos Juliann H. Panagos

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