Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 8/5/2015 1:37:11 PM JEFFREY D. KYLE Clerk No. 03-15-00292-CV THIRD COURT OF APPEALS 8/5/2015 1:37:11 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00292-CV *1 ACCEPTED [6367541] CLERK
I N THE OURT OF A PPEALS FOR THE
T HIRD J UDICIAL D ISTRICT OF T EXAS
AT A USTIN , T EXAS CITY OF AUSTIN,
Appellant – Defendant ,
V .
JENNIFER FRAME, Individually and as Personal Representative
of the Estate of John William Griffith, et al.,
Appellees – Plaintiffs . Appeal from the 53rd Judicial District Court of Travis County, Texas
Cause No. D-1-GN-12-003557 APPELLEES’ UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSE BRIEF
Appellees Jennifer Frame, Individually and as Personal Representative of the
Estate of John William Griffith, Greg Griffith, Cheryl Burris, and Diana Pulido file
this unopposed motion for extension of time to file their response brief, and in
support therefore would respectfully show as follows:
1. The current deadline for Appellees to file their response brief is August
12, 2015.
2. Appellees seek a 14-day extension to file its response brief, making its
brief due on or before August 26, 2015.
3. Counsel for Appellees has been heavily involved in numerous highly
complex matters in both state and federal court. This request is not for delay only,
but so that Appellees’ positions and arguments may be fully developed and presented
to this Court in a concise and persuasive fashion.
4. This is the second request to extend the deadline for Appellees’
response brief.
5. Counsel for Appellees has conferred with Counsel for the City of
Austin, who indicated she is unopposed to Appellees’ request for an extension of
time to file their response brief.
WHEREFORE, PREMISES CONSIDERED, Appellees respectfully request
an order granting their Unopposed Motion for Extension of Time to File Response
Brief so that Appellees’ response brief is due on or before August 26, 2015, and for
such other and further relief to which they may be justly entitled.
Dated: August 5, 2015 Respectfully submitted, H OWRY B REEN & H ERMAN , LLP
_______________________________ Sean E. Breen State Bar No. 00783715 sbreen@howrybreen.com H OWRY B REEN & H ERMAN , L.L.P. 1900 Pearl Street Austin, Texas 78705 Tel. (512) 474-7300 Fax (512) 474-8557 Mike Davis State Bar No. 05549500 mdavis@slackdavis.com S LACK & D AVIS , L.L.P. 2705 Bee Cave Road, Suite 220 Austin, Texas 78746 Tel. (512) 795-8686 Fax (512) 795-8787 Attorneys for Appellees ERTIFICATE OF C ONFERENCE I hereby certify that on August 5, 2015, I conferred with Counsel for Appellant by
e-mail regarding the relief sought by this motion, and she indicated the motion is
unopposed. Sean E. Breen ERTIFICATE OF S ERVICE
I certify that a true and correct copy of this document was delivered on August 5,
2015, in compliance with Rules 9.5(b) of the Texas Rules of Appellate Procedure,
to the parties listed and in the manner indicated below. Electronic service
Chris Edwards
Assistant City Attorney □ In person
City of Austin - Law Department □ Registered mail, return receipt requested
P.O. Box 1546 □ Commercial delivery service
Austin, Texas 78767-1546 □ Facsimile
Tel. (512) 974-2419 Electronic mail
Fax (512) 974-1311
chris.edwards@austintexas.gov
Attorney for Defendant – Appellant
City of Austin
Sean E. Breen