Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 11/13/2015 1:51:53 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00387-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 11/13/2015 1:51:53 PM CHRISTOPHER PRINE CLERK No. 14-15-00387-CV
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In the Court of Appeals for the
Fourteenth District of Texas at Houston
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S HAYN A. P ROLER
Appellants V .
C ITY OF H OUSTON ,
Appellee _______________________________________________
On Appeal from the 234th Judicial District Court
Harris County, Texas
Trial Court Case No. 2007-30944
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Unopposed Motion for Extension of Time
to File Appellee’s Brief
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TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
Appellee respectfully requests a thirty-day extension of time to file its
Appellee’s Brief, up to and including December 16, 2015, and in support
respectfully shows as follows:
1. Appellant’s Brief was filed October 16, 2015, generating a due date for
Appellee’s Brief of November 16, 2015.
2. This is the first motion for an extension of time to file the brief. It is
unopposed.
3. The undersigned has a busy appellate practice, including related trial
court motions and hearings, with the City. Among other briefs the
undersigned has been, and continues to be, working on during this
briefing period are:
a. No. 15-20237, Ricardo Salazar-Limon v. City of Houston, et al. , in the
United States Court of Appeals for the 5th Circuit, Appellees’ Brief
due November 18, 2015;
b. In re City of Houston , No. 15-_____, in the Supreme Court of Texas,
anticipated filing date November 23, 2015.
4. The undersigned has conferred with the attorney for Appellant and he
does not oppose the extension.
5. This motion is not for delay but so that justice may be done.
For these reasons, Appellee respectfully asks that the Court grant it a
thirty-day extension of time to file its brief, and grant any other relief to which
it is entitled.
Respectfully submitted,
D ONNA L. E DMUNDSON
City Attorney
J UDITH L. R AMSEY
Chief, General Litigation Section
By: /s/ Robert W. Higgason
Robert W. Higgason Senior Assistant City Attorney State Bar No. 09590800 City of Houston Legal Department 900 Bagby, 3rd Floor Houston, Texas 77002 Telephone: 832.393.6481 Facsimile: 832.393.6259 robert.higgason@houstontx.gov Attorneys for Appellee
Certificate of Conference
I hereby certify that I have conferred with Appellant’s counsel and that
Appellant is unopposed to this motion.
/s/ Robert W. Higgason
Robert W. Higgason
Certificate of Service
I hereby certify that on November 13, 2015, a true and correct copy of
the foregoing has been served on counsel below via e-service.
David T. Lopez
D AVID T. L OPEZ & A SSOC .
3900 Montrose Blvd.
Houston, Texas 77006-4959
dtlopez@lopezlawfirm.com
Attorney for Appellant
/s/ Robert W. Higgason
Robert W. Higgason