No. _____ I
N THE
S
UPREME
C
OURT OF
T
EXAS
S
TEVEN
G
REGORY
S
LOAT
,
E
D
B
RYAN
,
C
HURCH OF
S
CIENTOLOGY
I
NTERNATIONAL
,
D
AVID
J.
L
UBOW
,
AND
M
ONTY
D
RAKE
,
Petitioners,
v. M
ONIQUE
R
ATHBUN
,
Respondent.
On Petition for Review from the Third Court of Appeals at Austin Texas No. 03-14-00199-CV
U
NOPPOSED
F
IRST
M
OTION FOR
E
XTENSION OF
T
IME
TO
F
ILE
P
ETITION FOR
R
EVIEW
Petitioner Church of Scientology International respectfully files this Unopposed First Motion for Extension of Time to File Petition for Review. The current deadline for filing the petition is
December 21, 2015
. Petitioner requests a
30-day
extension
of time for a new a new deadline of
January 20, 2016
.
The reasons for this request are as follows: For the past several months, the undersigned counsel has spent a considerable amount of time preparing for oral argument to the Fourteenth Court of Appeals in a case reversed and remanded to that
15-0966
FILED
15-0966
12/16/2015 4:39:49 PM
tex-8271611
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK
2 court from this Court in
Zachry Constr. Corp. v. Port of Houston Authority
, 449 S.W.3d 98 (Tex. 2014). That preparation has included reviewing approximately 50 volumes of trial transcript covering a three-month trial. The oral argument was finally held in that case this past Monday, December 14, 2005, just one week before the petition for review is due in this case. Other work by the undersigned counsel during this time frame has included drafting Petitioner’s Brief on the Merits in No. 15-0368,
Walsh v. Woundkair Concepts, Inc.
, which is due to be filed on Wednesday, December 23, 2015, just two days after the deadline for the petition in this case. This extension is not sought for the purposes of delay. No prior extension has been granted for this deadline. As set forth in the Certificate of Conference below, this motion for extension of time is unopposed. For these reasons, petitioner Church of Scientology International requests that its Unopposed First Motion for Extension of Time be granted, and that the deadline for filing its petition for review be extended 30 days to January 20, 2016.
3 Respectfully submitted, /s/ Douglas W. Alexander Douglas W. Alexander State Bar No. 00992350 dalexander@adjtlaw.com A
LEXANDER
D
UBOSE
J
EFFERSON
&
T
OWNSEND LLP
515 Congress Avenue, Suite 2350 Austin, Texas 78701-3562 Telephone: (512) 482-9300 Facsimile: (512) 482-9303 Thomas S. Leatherbury State Bar No. 12095275 tleatherbury@velaw.com Marc A. Fuller State Bar No. 24032210 mfuller@velaw.com V
INSON
& E
LKINS
LLP Trammell Crow Center 2001 Ross Avenue, Suite 3700 Dallas, Texas 75201 Telephone: (214) 220-7792 Facsimile: (214) 999-7792
C
OUNSEL FOR
C
HURCH OF
S
CIENTOLOGY
I
NTERNATIONAL
C
ERTIFICATE OF
C
ONFERENCE
I certify that on November 23, 2015, I conferred with Leslie Hyman, counsel for Respondent, and she stated that her client does not oppose the relief sought in this motion for extension of time. /s/ Douglas W. Alexander Douglas W. Alexander