Philip Wayne Hindes and Melinda Hindes Eustace v. La Salle County, Texas The Honorable Joel Rodriguez Jr., in His Official Capacity as County Judge, La Salle County, Texas And the Honorable Raul Ayala, in His Official Capacity as County Commissioner, Precinct 4, La Salle County, Texas

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ACCEPTED 04-14-00651-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 2/17/2015 11:30:37 AM KEITH HOTTLE CLERK NO. 04-14-00651-CV FILED IN IN THE COURT OF APPEALS 4th COURT OF APPEALS FOURTH COURT OF APPEALS DISTRICTSAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 2/17/2015 11:30:37 AM KEITH E. HOTTLE Clerk PHILIP WAYNE HINDES AND MELINDA HINDES EUSTACE, Appellants v. LA SALLE COUNTY, TEXAS, HON. JOEL RODRIGUEZ, JR., IN HIS OFFICIAL CAPACITY AS COUNTY JUDGE, LA SALLE COUNTY, TEXAS, AND HON. RAUL AYALA, IN HIS OFFICIAL CAPACITY AS COUNTY COMMISSIONER, PRECINCT 4, LA SALLE COUNTY, TEXAS. Appellees ON APPEAL FROM THE 81ST DISTRICT COURT, LA SALLE COUNTY, TEXAS HONORABLE DICK ALCALA PRESIDING CAUSE NO. 12-09-00179-CVL UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF TO THE HONORABLE FOURTH COURT OF APPEALS: Appellants respectfully present this unopposed first motion to extend the time in which to file their Appellants’ Reply Brief pursuant to Texas Rule of Appellate Procedure 38.6. No previous motions for extension of time to file the Appellants’ Reply Brief have been filed. In support of this motion, appellants would show the Court as follows: I. Appellants’ Reply Brief is currently due on February 25, 2015. Because of the events and matters described more fully below, appellants request an extension of an additional 30 days in which to file the Appellants’ Reply Brief or until March 27, 2015. II. The requested extension is necessary because the following matters have prevented the undersigned from completing the Appellants’ Reply Brief and will preclude the undersigned from doing so sooner than March 27, 2015: 1. The undersigned prepared motions to exclude evidence in order to meet a pretrial deadline in Martha Elvia Bolanos et al. v. General Motors et al., No. 7,478, in the 49th Judicial District Court, Zapata County, Texas; 2. The undersigned had to prepare legal research and analysis to prepare for an appellate mediation in Dennis Rayner and Joe Tex Xpress, Inc. v. Krista Dillon, No. 06-15-00009-CV, in the Texarkana Court of Appeals; 3. The undersigned completed legal research in connection a proposed jury charge in Marvin Stoxstell v. Union Pacific Railroad Co. et al., No. 2012-54418, in the 55th Judicial District Court, Harris County, Texas; and 4. The undersigned was nominated to run for President-Elect of the Texas Young Lawyers Association and has had expended considerable time preparing for the campaign. For all of the reasons explained above, counsel for appellants cannot complete the Appellants’ Reply Brief by its current due date of February 25, 2015, and needs an additional 30 days in which to do so. 2 III. On February 16, 2015, the undersigned conferred with Michael Shaunessy, lead appellate counsel for appellees. Mr. Shaunessy indicated that this motion would not be opposed. WHEREFORE, PREMISES CONSIDERED, appellants respectfully request that this Court grant their motion for extension of time in which to file the Appellants’ Reply Brief, extend the deadline in which to file the brief an additional 30 days up to and including March 27, 2015, and grant such other and further relief to which appellants may be justly and equitably entitled. Respectfully submitted, /s/ Samuel V. Houston, III SAMUEL V. HOUSTON, III State Bar No. 24041135 Direct Line: (210) 775-0882 HOUSTON DUNN, PLLC 4040 Broadway, Suite 440 San Antonio, Texas 78209 Telephone: (210) 775-0880 Fax: (210) 826-0075 sam@hdappeals.com ATTORNEY FOR APPELLANTS 3 CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoing motion has been served on the following counsel in accordance with the Texas Rules of Appellate Procedure, on this 17th day of February, 2015: Christopher S. Johns Via email/e-service JOHNS MARRS ELLIS & HODGE LLP 805 West 10th Street, Suite 400 Austin, Texas 78701 cjohns@jmehlaw.com Michael S. Shaunessy Via email/e-service MCGINNIS LOCHRIDGE, LLP 600 Congress Ave, Suite 2100 Austin, Texas 78701 MShaunessy@mcginnislaw.com Dan Miller Via email/e-service MCELROY, SULLIVAN, MILLER WEBER & OLMSTEAD, LLP P.O. Box 12127 Austin, Texas 78711 dmiller@msmtx.com /s/ Samuel V. Houston, III SAMUEL V. HOUSTON, III 4