Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 6/17/2015 2:24:01 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00280-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/17/2015 2:24:01 PM CHRISTOPHER PRINE CLERK N O . 14-15-00280-CV I N THE C OURT OF A PPEALS
F OURTEENTH J UDICIAL D ISTRICT
H OUSTON , T EXAS C ONRAD C ONSTRUCTION C O ., L TD .
A PPELLANT VS .
F REEDMEN ’ S T OWN P RESERVATION C OALITION ,
C ATHERINE R OBERTS AND G LADYS H OUSE
A PPELLEES F ROM THE 80 TH J UDICIAL D ISTRICT C OURT
OF H ARRIS C OUNTY T EXAS
(T RIAL OURT C AUSE N O . 2015-02771) A PPELLEES ’ U NOPPOSED M OTION FOR L EAVE
TO ILE R ESPONSE B RIEF O UT - OF -T IME T O THE H ONORABLE OURT OF A PPEALS :
Appellees Freedmen’s Town Preservation Coalition, Catherine
Roberts and Gladys House file this Second Unopposed Motion for
Extension of Time to file Response Brief and would respectfully show the
Court the following:
1. In this interlocutory appeal from a temporary injunction entered
by the 80 Judicial District Court of Harris County, Texas, Appellant Conrad
Construction Co., Ltd. filed its initial brief on April 24, 2015. Pursuant to
Tex.R.App.Pro. 38.6(b), Appellees’ responsive brief was initially due May
13, 2015. This Court, however, granted Appellees’ Unopposed Motion for
Extension of Time to File Response Brief extending the date for Appellees
to file their brief to and through June 12, 2015.
2. On June 9, 2015, Appellees filed their Second Unopposed
Motion for Extension of Time to File Response Brief, requesting that the
Court further extend the date for filing Appellees’ Response Brief to and
through June 26, 2015, due to intermittent internet outages Appellees’
counsel suffered during and after the storms which inundated the Houston
and Harris County area during the Memorial Day holidays. That motion
has yet to be ruled upon by the Court.
3. Appellees’ counsel has now completed the Response Brief and
has efiled it with the Court simultaneously with this Motion. Appellees
accordingly request leave of the Court to file their Response Brief five days
subsequent to its due date of June 12, 2015, as extended previously by this
Court.
4. Counsel for Appellant, Robert A. Plessala, has advised the
undersigned counsel for Appellees that he does not oppose the relief
requested by this Motion.
W HEREFORE PREMISES CONSIDERED , Appellees respectfully request
that the Court grant Appellees leave to file their Response Brief five days
after the extended due date previously ordered by the Court.
S IGNED AND ILED this 17 day of June, 2015.
Respectfully submitted, T HE H ALL L AW F IRM /s/William L. Van Fleet Benjamin L. Hall III Texas Bar No. 08743745 William L. Van Fleet II Texas Bar No. 20494750 Kimmie R. Bennett State Bar No. 24011946 530 Lovett Blvd.
Houston, TX 77006 (713) 942-9600 (Telephone) (713) 942-9566 (Facsimile) bvfleet@comcast.net A TTORNEYS FOR A PPELLEES REEDMEN ’ S T OWN P RESERVATION C OALITION C ATHERINE R OBERTS , AND G LADYS H OUSE ERTIFICATE OF ONFERENCE The undersigned certifies that on June 17, 2015, he conferred with
Robert A. Plessala, counsel for Appellant Conrad Construction Co., Ltd.,
who advised that he does not oppose the relief requested in the above and
foregoing Motion.
/s/William L. Van Fleet William L. Van Fleet II *5 ERTIFICATE OF OMPLIANCE (R ULE 9.4) The undersigned certifies that the above and foregoing Motion satisfies
the requirements of Tex.R.App.P. 9.4 because the Motion contains 556
words.
/s/William L. Van Fleet II William L. Van Fleet II CERTIFICATE OF SERVICE I hereby certify that on the 17 day of June, 2015, a true and correct
copy of the foregoing Motion was forwarded to counsel for Conrad
Construction Co., Ltd., Robert A. Plessala, Andrews Myers, P.C., 3900
Essex Lane, Suite 800, Houston, Texas 77027, via email at
rplessala@andrewsmyers.com.
/s/William L. Van Fleet William L. Van Fleet II