Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 10/6/2015 3:06:33 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00117-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 10/6/2015 3:06:33 PM CHRISTOPHER PRINE CLERK No. 01-15-00117-CV IN THE FIRST COURT OF APPEALS, HOUSTON League City, Appellant , v.
Texas Windstorm Insurance Association, Appellee . On Appeal from the 10th District Court at Galveston, Texas No. 12-CV-0053 UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S RESPONSIVE BRIEF dale.wainwright@bgllp.com State Bar No. 00000049 Lindsay E. Hagans State Bar No. 24087651 lindsay.hagans@bgllp.com B RACEWELL G IULIANI LLP 111 Congress Avenue, Suite 2300 Austin, Texas 78701 Telephone: (512) 472-7800 Facsimile: (800) 404-3970 ATTORNEYS FOR APPELLEE TEXAS WINDSTORM INSURANCE ASSOCIATION *2
Pursuant to Texas Rule of Appellate Procedure 10.5(b), Appellee Texas
Windstorm Insurance Association (“TWIA”) files its Second Motion for Extension
of Time to file its brief.
TWIA’s brief is currently due on October 8, 2015. This is TWIA’s second
request for an extension of thirty days in which to file its brief, which would make
the Brief of Appellee due on November 9, 2015. League City does not oppose this
requested extension.
TWIA needs a thirty-day extension of time to file its brief because since
filing the last motion for extension, counsel was set for oral argument on October
14, 2015, in the appeal Coyote Lake Ranch LLC v. the City of Lubbock , No. 14-
0572, in the Texas Supreme Court, and have briefs due in other appeals including
Westlake Ethylene Pipeline Corp. v. Railroad Commission of Texas , No. D-1-GN-
15-001009 in the 98th Judicial Distrct Court of Travis County, Texas
(administrative appeal that goes first to the District Court). Also, TWIA’s trial
counsel, whose institutional knowledge of this long and complicated case is
invaluable to the appeal, are in the midst of other Hurricane Ike litigation. A short,
thirty-day extension of time would allow for cogent, thoughtful preparation of the
brief.
PRAYER For these reasons, Appellee Texas Windstorm Insurance Association prays
this Court grant a thirty-day extension of time to file its brief, to and including
November 9, 2015. Appellee also prays for such further relief to which it may be
entitled.
Respectfully submitted, B RACEWELL G IULIANI LLP By: /s/ Dale Wainwright State Bar No. 00000049 Lindsay E. Hagans State Bar No. 24087651 111 Congress Avenue, Suite 2300 Austin, Texas 78701 Telephone: (512) 472-7800 Facsimile: (800) 404-3970 dale.wainwright@bgllp.com lindsay.hagans@bgllp.com ATTORNEYS FOR APPELLEE TEXAS WINDSTORM INSURANCE ASSOCIATION *4 CERTIFICATE OF CONFERENCE I certify that I have conferred with counsel for the Appellant League City
regarding the relief sought in this motion. Appellant League City is not opposed to
the relief sought in this motion.
/s/ Dale Wainwright Dale Wainwright CERTIFICATE OF SERVICE I certify that a copy of the Second Motion for Extension of Time to file
Appellee’s Brief was served on counsel of record through the Court’s e-filing
system on October 6, 2015, to the following:
Gregory F. Cox
Michael R. Ramsey
T HE M OSTYN L AW F IRM
6280 Delaware Street
Beaumont, Texas 77706
Facsimile: (409) 832-2703
Jennifer Bruch Hogan
H OGAN H OGAN
2 Houston Center
909 Fannin, Suite 2700
Houston, Texas 77010
Facsimile: 713-222-8810
Attorneys For Appellant
League City
/s/ Dale Wainwright