Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/22/2015 2:39:59 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00117-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/22/2015 2:39:59 PM CHRISTOPHER PRINE CLERK No. 01-15-00117-CV
In the
Court of Appeals for the First District of Texas LEAGUE CITY,
Appellant/Cross-Appellee, v.
TEXAS WINDSTORM INSURANCE ASSOCIATION, Appellees/Appellees.
SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLY BRIEF OF APPELLANT LEAGUE CITY TO THE HONORABLE COURT OF APPEALS:
Appellant, League City, under the authority of T EX . R. PP . P. 10.5(b), asks
for additional time to file its reply brief as appellant.
1. The reply brief of appellant is due January 20, 2016 after the Court
granted one extension request.
2. This is League City’s second request for an extension of time for
filing its reply brief as appellant. League City respectfully requests a 21-day extension of time for filing
its reply brief as appellant. With the extension, League City’s reply brief as
appellant will be due on Wednesday, January 20, 2016. *2 An extension is necessary and warranted because counsel has been
required to attend to other time-sensitive matters, including the following:
a. Preparation of respondent’s brief on the merits in No. 14-0721; USAA
Texas Lloyd’s Company v. Gail Menchaca ; in the Supreme Court of Texas, filed November 20, 2015.
b. Preparation of motion for rehearing in No. 01-14-00278-CV; John
Davis d/b/a J. D. House of Style v. National Lloyds Insurance Company ; in the First Court of Appeals, Houston, Texas, filed November 27, 2015.
c. Preparation for hearing on motion for final decree in No. 2014-30215;
In the Matter of the Marriage of Evangelina Lopez Guzman Zaragoza and Miguel Zaragoza Fuentes, et al. ; in the 245th District Court, Harris County, Texas; held December 14, 2015.
d. Preparation for hearing on motion for entry of judgment in No. 2013-
61098; Scott D. Martin and SKM Partnership, Ltd. v. Andrews Kurth LLP ; in the 234th District Court, Harris County, Texas; held December 14, 2015.
e. Preparation of response to claimant’s objections to continued service
of arbitrator in Arbitration No. 01-14-0001-3289; Amy Rozell, et al. v. Richard Pohil, M.D., et al. ; in the Arbitration Tribunals of the American Arbitration Association; filed December 18, 2015.
f. Preparation of cross-respondent’s brief on the merits in No. 14-1028;
Sun Development, L.P. v. Larry Hughes and Susan Hughes ; in the Supreme Court of Texas, due December 28, 2015.
g. Preparation of response to petition for review in No. 15-0642, Estate
of Alfredo M. Pagayon, Deceased and Delia Pagayon, et al. v. Exxon Mobil Corporation ; in the Supreme Court of Texas, due January 4, 2016.
h. Preparation of petitioner’s reply brief on the merits in No. 14-1028;
Sun Development, L.P. v. Larry Hughes and Susan Hughes ; in the Supreme Court of Texas, due January 12, 2016.
i. Preparation of brief of appellant in No. 14-15-00702-CV; Shabahram
Yazdani-Beioky v. Abdee Sharifan ; in the Fourteenth Court of Appeals, Houston, Texas, due January 13, 2016.
j. Preparation of real-party-in-interest’s brief on the merits in No. 15-
0452; In re National Lloyds Insurance Company ; in the Supreme Court of Texas, due January 27, 2015.
5. Counsel for appellant has conferred with counsel for appellee, Dale
Wainwright, and TWIA is unopposed to the requested extension. This request is not sought for delay, but in order that justice may be
done. See T EX . R. PP . P. 10.5(b)(1)(C).
PRAYER
Appellant, League City, asks this Court to grant an extension of 21 days,
until Wednesday, January 20, 2016, to file its reply brief as appellant. League City
also prays for any other relief to which it may be entitled.
Respectfully Submitted: T HE M OSTYN L AW F IRM H OGAN & H OGAN
Gregory F. Cox By:
State Bar No. 00793561
gfcox@mostynlaw.com State Bar No. 03239100
6280 Delaware Street jhogan@hoganfirm.com
Beaumont, Texas 77706 Richard P. Hogan, Jr.
409.832.2777–telephone State Bar No. 09802010
409.832.2703–facsimile rhogan@hoganfirm.com
James C. Marrow T HE M OSTYN L AW F IRM State Bar No. 24013103
jmarrow@hoganfirm.com Rene M. Sigman Pennzoil Place
State Bar No. 24037492 711 Louisiana, Suite 500
rmsigman@mostynlaw.com Houston, Texas 77002-2721
3810 W. Alabama 713.222.8800–telephone
Houston, Texas 77027 713.222.8810–facsimile
713.861.6616–telephone
713.861.8084–facsimile
Attorneys for Appellant *5 CERTIFICATE OF CONFERENCE Counsel for appellant has conferred with counsel for appellee, Dale
Wainwright, and TWIA is unopposed to the motion for extension of time to file
League City’s reply brief as appellant.
Dated: December 22, 2015 *6 CERTIFICATE OF SERVICE I certify that a true and correct copy of the above and foregoing was
forwarded to all counsel of record by the Electronic Filing Service Provider, if
registered; a true and correct copy of this document was forwarded to all counsel
of record not registered with an Electronic Filing Service Provider and to all other
parties as follows:
Counsel for Texas Windstorm Insurance Association:
Dale Wainwright
B RACEWELL & G IULIANI LLP
111 Congress Avenue Suite 2300
Austin, Texas 78701-4061
Via TexFile
Andrew T. McKinney IV
L ITCHFIELD C AVO LLP
One Riverway, Suite 1000
Houston, Texas 77056
Via TexFile
James R. Old, Jr.
J AY O LD & SSOCIATES , PLLC
3560 Delaware, Suite 308
Beaumont, Texas 77706
Via TexFile
Dated: December 22, 2015