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