Cecil Adams and Maxine Adams v. Harris County and Christopher A. Prine, Clerk of the First Court of Appeals

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ACCEPTED 04-15-00287-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 7/2/2015 5:05:22 PM KEITH HOTTLE CLERK No. 04-15-00287-CV ______________________________ FILED IN IN THE COURT OF APPEALS 4th COURT OF APPEALS SAN ANTONIO, TEXAS 07/2/2015 5:05:22 PM FOR THE FOURTH JUDICIAL DISTRICT KEITH E. HOTTLE Clerk SAN ANTONIO, TEXAS ______________________________ Cecil and Maxine Adams, Plaintiffs - Appellants, vs. Harris County, Rebecca Ross, Kathleen Keese and Christopher Prine, Clerk of the First Court of Appeals, Defendants - Appellees. ______________________________ On Appeal from the 269th District Court of Harris County, Texas Trial Court Cause No. 2014-35653 APPELLEES’ JOINT MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS: Defendant-Appellees Harris County and Christopher Prine, District Clerk for the First Court of Appeals, move for a 20-day extension of time to file their briefs in response to Plaintiff-Appellant Adams= brief. This is the first extension sought by Appellees in this interlocutory appeal. Further, Appellants were afforded an 1 extension of time to file their brief. Currently, Appellees’ briefs are due on July 9, 2015. The undersigned contend that the need for an extension is not due to sloth or neglect, and is not requested for the purpose of delay. An extension is requested so that counsel may have adequate time to review the clerk and reporters records, their own records, and file thorough briefs, thereby preserving judicial economy. Therefore, Appellees respectfully request a 20-day extension to file Appellees’ briefs. Respectfully submitted, KEN PAXTON Attorney General of Texas CHARLES E. ROY First Assistant Attorney General JAMES E. DAVIS Deputy Attorney General for Civil Litigation KAREN D. MATLOCK Assistant Attorney General Chief, Law Enforcement Defense Division /s/ Christin Cobe Vasquez CHRISTIN COBE VASQUEZ Assistant Attorney General State Bar No. 24074047 Christin.vasquez@texasattorneygeneral.gov 2 P.O. Box 12548, Capitol Station Austin, Texas 78711 (512) 463-2080 / Fax (512) 936-2109 ATTORNEYS FOR DEFENDANT- APPELLEE CHRISTOPHER PRINE -AND- /s/ Keith A. Toler KEITH A. TOLER Assistant County Attorney State Bar No. 24088541 1019 Congress, 15th Floor Houston, Texas, 77002 Phone: (713) 274-5265 Fax: (713) 755-8924 Email: Keith.Toler@cao.hctx.net ATTORNEY FOR APPELLEE HARRIS COUNTY CERTIFICATE OF CONFERENCE I, KEITH A. TOLER, attempted to confer with Appellants via email regarding the substance of this motion on Wednesday, July 1, 2015; however, as of the time of filing this motion I did not receive any response. Therefore, it must be assumed that Appellants oppose this motion. /s/ Keith Toler KEITH TOLER Assistant County Attorney CERTIFICATE OF SERVICE I, CHRISTIN COBE VASQUEZ, Assistant Attorney General of Texas, certify that a true copy of Appellees’ Joint Motion for Extension of Time to File Response Brief was served upon all counsel of record via electronic filing notification, email and/or FedEx Overnight, return receipt requested, on July 2, 2015, addressed to: Jayson Booth Maxine Adams FedEx Overnight ATTORNEY FOR KATHLEEN Cecil Adams KEESE 5510 South Rice # 1206 3730 Kirby Drive, Ste 777 Houston, TX 77081 Houston, TX 77098 PRO SE (p) 713.280.9312 Cecillovesmax@sbcglobal.net (f) 713.526.1175 Swayne.adams@yahoo.com Email: info@boothricheylaw.com Brian A. Quintero Timothy Henderon Keith A. Toler COUNSEL FOR REBECCA ROSS ASST. COUNTY ATTORNEY 6300 West Loop South, Ste 280 1019 Congress 1th Floor Houston, TX 77401 Houston, TX 77002 (f) 713.688.5697 Brian.Quintero@cao.hctx.net timjhenderson@msn.com Keith.toler@cao.hctx.net Clinton Gambill ASST. COUNTY ATTORNEY 1019 Congress 1th Floor Houston, TX 77002 (p)713-755-5101 (f)713-755-8924 Clinton.Gambill@cao.hctx.net /s/ Christin Cobe Vasquez Christin Cobe Vasquez Assistant Attorney General 4 NOTICE OF ELECTRONIC FILING I, CHRISTIN COBE VASQUEZ, Assistant Attorney General of Texas, certify that I have electronically submitted the foregoing motion for filing in accordance with the Electronic File and Serve System for the Fourth Court of Appeals on July 2, 2015. /s/ Christin Cobe Vasquez Christin Cobe Vasquez Assistant Attorney General 5