Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 2/17/2015 4:54:42 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00900-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/17/2015 4:54:42 PM CHRISTOPHER PRINE CLERK NO. 14-14-00900-CVV

IN THE FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS

Steve Griffith in his Official Capacity, Douglas Brinkley in his Official Capacity,

Scott Schultz in his Official Capacity, and Mark Grothaus in his Official Capacity,

Appellants,

v. Collision Clinic, L.L.P. and Hanna “John” Elias, Appellees.

APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ RESPONSE BRIEF

COME NOW, Collision Clinic, L.L.C. and Hanna “John” Elias, Appellees herein, and move the Court for an extension of time to file Appellees’ Response

Brief in this cause, and in support thereof would show the Court as follows:

I. This is an interlocutory appeal on an order denying a plea to the jurisdiction pursuant to §51.014(a)(5) and (8), Tex. Civ. Prac. & Rem. Code. Appellants filed

their brief on or about January 21, 2015. Subsequently, a supplemental clerks

record was filed January 29, 2015. Appellees’ brief in response was due February

10, 2015.

II. This is Appellees’ first request for an extension of time to file Appellees’ *2 Brief.

III. Appellees hereby request a three week extension of time to file Appellees’ Response Brief until the 3 rd day of March 2015, and as reasons therefore would show

the Court as follows:

The undersigned counsel has been in numerous depositions and hearings and has had numerous briefs due in other matters in the last thirty days and therefore has

not been able to devote sufficient amount of time to the review of this entire record

and the preparation of the brief. In addition, the City of Sugar Land recently

adopted a resolution related to the underlying issue in the present lawsuit and

counsel for Appellees have needed time to analyze the impact of the resolution on

the present litigation.

IV. Appellees have advised counsel for Appellants of their intent to file this Motion for Extension of Time and requested they advise whether they are opposed

or unopposed. At the time of this filing, counsel for Appellees have not received a

response to their request.

WHEREFORE, PREMISES CONSIDERED, the undersigned counsel respectfully prays that this Honorable Court extend the time for filing the Appellees =

Response Brief in this cause until the 3 rd day of March, 2015.

Respectfully submitted, T HE I RWIN L AW F IRM , P.C.

By: /s/ Leland M. Irwin Leland M. Irwin State Bar No. 00790945 leland@irwin-lawfirm.com 210 Morton Street Richmond, Texas 77469 (832) 847-4111 Facsimile (832) 847-4177 - AND -

Y OUNG AND H USAIN , P.L.L.C.

By: /s/ Omar Khawaja Omar Khawaja State Bar No. 24072181 okhawaja@yhlawfirm.com 2700 Post Oak Blvd., Suite 1220 Houston, Texas 77056 713-621-8900 Facsimile 713-621-8909 A TTORNEYS FOR R EAL P ARTIES IN I NTEREST C OLLISION C LINIC , L.L.C. AND H ANNA “J OHN ” E LIAS

VERIFICATION

STATE OF TEXAS §

COUNTY OF FORT BEND §

BEFORE ME, the undersigned Notary Public, on this day personally appeared, Leland M. Irwin, who being by me duly sworn on his oath deposed and

said that he is the attorney for Collision Clinic, L.L.C. and Hanna "John" Elias,

Appellees in the above-entitled and numbered cause; that he has read the above and

foregoing Motion For Extension of Time to File Appellees' Response Brief; and that

every statement contained therein is within h. owledge and is true and correct. SHERRIE MONTGOMERY

MY COMMISSION EXPIRES March 9, 2015 Notary Public in and for the State of Texas CERTIFICATE OF CONFERENCE This is to certify that on February 17, 2015, I have attempted to confer with Patricia L. Hayden, counsel for Appellants, via email regarding this Motion for

Extension of Time to File Appellees' Response Brief, and that she has not responded

to my request.

Isl Leland M Irwin Leland M. Irwin

CERTIFICATE OF SERVICE I hereby certify that on February 17, 2015, a true and correct copy of this document was served on the following counsel and respondent:

E-serve and Email: PHayden@OlsonLLP.com

Patricia L. Hayden

Olson & Olson, L.L.P.

209 e. Mulberry, Suite 100

Angleton, Texas 77515

Attorney for Defendants Steve Griffith,

Douglas Brinkley, Scott Schultz, and

Mark Grothaus

E-Serve and Email: don@dontschwartzlaw.com

Don T. Schwartz

Schwartz & Kalinowski, L.L.P.

1821 Mons Avenue

Rosenberg, TX 77471

Attorney for Defendant

A & M Wrecker Service

Facsimile 281/238-8514

And Email: mcdougal-law-larry@comcast.net

Larry P. McDougal

809 Houston St.

Richmond, TX 77469

Attorney for Defendant

J&H Towing and Recovery

Facsimile 713/802-1339

Dan Reiver

1445 North Loop West, Suite 900

Houston, TX 77008

Attorney for Defendant

Long’ Towing, LLC

Facsimile 281/250-4253

Francisco R. Yeverino

112 W. 4 th Street

Houston, TX 77007

Attorney for Defendant

Big Rod’s Towing, Inc.

Facsimile 713/789-7703

Daniel F. Castaneda

Buckley, White, Castaneda & Howell, L.L.P.

2401 Fountainview, Suite 1000

Houston, Texas 77057

Attorney for Defendant

Russell Rossett and Hadjes, Inc.

/s/ Leland M. Irwin Leland M. Irwin