Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 8/5/2015 1:59:07 PM JEFFREY D. KYLE Clerk No. 03-15-00377-CV THIRD COURT OF APPEALS 8/5/2015 1:59:07 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00377-CV *1 ACCEPTED [6368348] 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 LEANDER, et al.,
Appellants – Defendants ,
V .
PREMAS GLOBAL LEANDER I, LLC,
Appellee – Plaintiff . Appeal from the 277th Judicial District Court of Williamson County, Texas
Cause No. 15-0088-C277 APPELLEE’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSE BRIEF
Appellee Premas Global Leander I, LLC (Premas) files this unopposed motion
for extension of time to file its response brief, and in support therefore would
respectfully show as follows:
1. The current deadline for Premas to file its response brief is August 10,
2015.
2. Premas seeks a 21-day extension to file its response brief, making its
brief due on or before August 31, 2015.
3. Counsel for Premas 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 Premas’s positions and arguments may be fully developed and presented
to this Court in a concise and persuasive fashion.
4. This is the first request to extend the deadline for Premas’s response
brief.
5. Counsel for Premas has conferred with Counsel for Appellants, who
indicated he is unopposed to Premas’s request for an extension of time to file its
response brief.
WHEREFORE, PREMISES CONSIDERED, Premas respectfully requests an
order granting its Unopposed Motion for Extension of Time to File Response Brief
so that Premas’s response brief is due on or before August 31, 2015, and for such
other and further relief to which it may be entitled.
Dated: August 5, 2015 Respectfully submitted,
H OWRY B REEN & H ERMAN , LLP _______________________________ Sean E. Breen State Bar No. 00783715 sbreen@howrybreen.com Randy R. Howry State Bar No. 10121690 rhowry@howrybreen.com James Hatchitt State Bar No. 24072478 jhatchitt@howrybreen.com 1900 Pearl Street Austin, Texas 78705-5408 Tel. (512) 474-7300 Fax (512) 474-8557 Attorneys for Plaintiff – Appellee Premas Global Leander I, LLC ERTIFICATE OF C ONFERENCE I hereby certify that on August 5, 2015, I conferred with Counsel for Appellants by
e-mail regarding the relief sought by this motion, and he 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
Bradford E. Bullock
bradford@cityattorneytexas.com □ In person
K NIGHT & P ARTNERS □ Registered mail, return receipt requested
Executive Office Terrace □ Commercial delivery service
223 West Anderson Lane, Suite A- □ Facsimile
105 Electronic mail
Austin, Texas 78752
Tel. (512) 323-5778
Fax (512) 323-5773
Attorney for Defendants – Appellants
City of Leander, Kent Cagle, and
Thomas Yantis Sean E. Breen