Connie Rogge, Individually and as Heir of Richard Hollas Rogge, Richard Rogge, Individually and as Heir of Richard Hollas Rogge and Richard Rogge as Administrator of the Estate of Richard Hollas Rogge v. the City of Richmond, Texas, Todd Ganey and Danell Gaydos

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ACCEPTED 01-14-00866-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 1/26/2015 1:12:03 PM CHRISTOPHER PRINE CLERK NO. 01-14-00866-CV ______________________________________ FILED IN 1st COURT OF APPEALS IN THE FIRST COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 1/26/2015 1:12:03 PM ______________________________________ CHRISTOPHER A. PRINE Clerk CONNIE ROGGE, Individually and as heir of Richard Hollas Rogge; RICHARD ROGGE, Individually and as Heir of Richard Hollas Rogge; and RICHARD ROGGE as Administrator of the Estate of RICHARD HOLLAS ROGGE, Plaintiffs-Appellants, vs. THE CITY OF RICHMOND, TEXAS; TODD GANEY; and DANELL GAYDOS, Defendants-Appellees. ______________________________________ On Appeal from the 268th Judicial District Court of Fort Bend County, Texas Trial Court Cause No. 11-DCV-194261 ______________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF ______________________________________ CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY WILLIAM S. HELFAND NORMAN RAY GILES 1200 Smith Street, Suite 1400 Houston, Texas 77002-4401 Tel: (713) 654-9630; Fax: (713) 658-2553 ATTORNEYS FOR APPELLEE, THE CITY OF RICHMOND, TEXAS TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW, The City of Richmond, Texas, Appellee herein, by and through its undersigned counsel, and files this Unopposed Motion for Extension of Time to File Appellee’s Brief in compliance with Rules 38.6(d) and 10.5 of the Texas Rules of Appellate Procedure. In support of this motion, Appellee would show as follows: 1. Appellee’s brief is currently due on January 28, 2015. 2. This is Appellee’s first request for an extension of time in which to file its brief. 3. Appellee requests a twenty-one day extension of time to file its brief, up to and including February 18, 2015. 4. Appellee is requesting this extension so that it might adequately brief the issues in dispute in this case, and it is not sought for the purpose of an improper delay. 5. The good cause which requires Appellee’s counsel to seek an extension is as follows. The undersigned counsel has responsibility for preparation of Appellee’s brief on appeal, but has been unable to complete the brief by January 28, 2015, due to his involvement in the following matters which are within the personal knowledge of the undersigned. 1 a. January 12, 2015 - SOAH Docket No. XXX-XX-XXXX.F-5 Administrative Hearing; Pamela A. Guerra v. Arcola Police Department b. January 15, 2015 – Status conference with Court; C.A. no. 4:09-cv-03332; Steve Hobart, et al v. City of Stafford, et al; U.S. District Court, Southern District of Texas c. January 16, 2015 – Hearing – C.A. No. 4:14-cv-03135; Michael Williams, et al v. John W. Focke, et al; U.S. District Court, Southern District of Texas d. January 19, 2015 – Mediation in Los Angeles, CA on Case No. 37-2014-00006422-CU-OE-CTL; Audrey Stanford, et al v. GC Services Ltd. Partnership; e. January 21, 2015 – hearing on Motion for Summary Judgment in Richmond, TX; Cause No. 12-DCV-200051 Fort Bend Co.; Leon Kaplan v. City of Sugar Lane; 240th District Court of Fort Bend County, Texas f. January 23, 2015 – Speaking engagement at an Employment Law Seminar. 6. The undersigned has conferred with counsel for the Appellant, and the Appellant is unopposed to this motion. WHEREFORE, PREMISES CONSIDERED, Appellee respectfully requests this court grant an extension of twenty-one (21) days to allow Appellee to file its brief, up to and including February 18, 2015. Appellee further requests general relief. 2 Respectfully submitted, CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY By: /s/ William S. Helfand WILLIAM S. HELFAND Attorney-in-Charge SBOT # 09388250 Norman Ray Giles SBOT # 24014084 ATTORNEYS FOR APPELLEE, THE CITY OF RICHMOND, TEXAS OF COUNSEL: CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & AUGHTRY 1200 Smith Street, Suite 1400 Houston, Texas 77002-4401 (713) 654-9630 (713) 658-2553 (Fax) 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been served via hand delivery, electronic submission, facsimile, U.S. Mail, and/or certified mail, return receipt requested, on this the 26th day of January, 2015, to the following: L. James Krell Ron S. Rainey Tritico Raney, PLLC 1212 Durham Drive Houston, Texas 77007 jkrell@triticorainey.com rrainey@triticorainey.com Neil C. McCabe The McCabe Law Firm Post Office Box 301101 Houston, Texas 77230 neilm@ncmlegal.com /s/ William S. Helfand 1706428_1 4