Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/15/2017 11:56:10 AM JEFFREY D. KYLE Clerk No. 03-17-00603-CV THIRD COURT OF APPEALS 12/15/2017 11:56 AM JEFFREY D. KYLE AUSTIN, TEXAS 03-17-00603-CV *1 ACCEPTED [21320112] CLERK IN THE COURT OF APPEALS FOR THE THIRD JUDICIAL DISTRICT TRAVIS COUNTY, TEXAS T EXAS D EPARTMENT OF A GRICULTURE , Defendant-Appellant, v.
S HEILA L ATTING , Plaintiff-Appellee .
On Appeal from Cause No. D-1-GN-16-000284, in the
201 st Judicial District, Travis County, Texas APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE APPELLEE’S BRIEF
Appellee, Sheila Latting (“Latting”) files this unopposed request for a
fourteen-day extension, and in support hereof, would show as follows:
1. Latting’s brief is currently due on December 21, 2017.
2. Latting seeks an extension of fourteen days to January 5, 2018, to
file its Appellee’s Brief. A motion to extend the time to file a brief may be filed before or
after the date a brief is due. See Tex. R. App. P. 38.6(d). Pursuant to
Texas Rule of Appellate Procedure 10.5(b)(1), a motion to extend the
time to file a brief must contain “(A) the deadline for filing the item in
question; (B) the length of the extension sought; (C) the facts relied on
to reasonably explain the need for an extension; and (D) the number
of previous extensions granted regarding the item in question.” Attorneys for Latting are related family members. Susan J. Haney,
the lead attorney, is the mother of Caitlin Haney Johnston, the
associate attorney, and Amber L. Haney, the sole paralegal for the
Haney Law Firm. There are no other full-time staff at the Haney Law
Firm. On December 4, 2017, the father of Caitlin Haney Johnston and
Amber Haney was admitted to the Emergency Room at St. David’s
South Austin with a life-threatening condition. Mr. Haney has been
discharged from St. David’s but will require significant rehabilitation
for at least several weeks. The undersigned has had to spend a
significant amount of time dealing with the family emergency over the
past two weeks. Susan J. Haney, as a result of the undersigned’s
absence from the office, has had to cover the hearings, mediations and
client meetings of all attorneys in the office during that time. As a
result, Appellee respectfully requests a fourteen-day extension so that
its counsel can have sufficient time to brief this appeal. This is Appellee’s first request for an extension in this case. This
request is sought, not for purposes of delay, but so that proper briefing
of this case may be presented to the Court and so that justice may be
done.
Date: December 15, 2017
Respectfully submitted, THE HANEY LAW FIRM 808 W 10 th Street, Suite 100 Austin, Texas 78701 (512) 476-2212 Fax: (512) 476-2202 www.thehaneylawfirm.com By: /s/ Caitlin Haney Johnston Susan J. Haney State Bar No. 08908550 susan@thehaneylawfirm.com Caitlin Haney State Bar No. 24087661 Caitlin@thehaneylawfirm.com ATTORNEYS FOR APPELLEE *4 CERTIFICATE OF CONFERENCE On December 13, 2017, the undersigned conferred by phone with counsel for
Appellant, who indicated he is unopposed to the requested extension.
/s/ Caitlin Haney Johnston Caitlin Haney Johnston CERTIFICATE OF SERVICE This is to certify that the above and foregoing pleading has this day been
served on this 15th day of December, 2017, by email to the following:
Drew L. Harris Via E-Filing
Assistant Attorney General
General Litigation Division
P.O. Box 12538, Capitol Station
Austin, Texas 78767
ATTORNEYS FOR DEFENDANT
/s/ Caitlin Haney Johnston
Caitlin Haney Johnston