ACCEPTED
01-15-00117-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/22/2015 2:39:59 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00117-CV
FILED IN
1st COURT OF APPEALS
In the HOUSTON, TEXAS
12/22/2015 2:39:59 PM
Court of Appeals CHRISTOPHER A. PRINE
Clerk
for the First District of Texas
LEAGUE CITY,
Appellant/Cross-Appellee,
v.
TEXAS WINDSTORM INSURANCE ASSOCIATION,
Appellees/Appellees.
SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLY BRIEF OF APPELLANT LEAGUE CITY
TO THE HONORABLE COURT OF APPEALS:
Appellant, League City, under the authority of TEX. R. APP. P. 10.5(b), asks
for additional time to file its reply brief as appellant.
1. The reply brief of appellant is due January 20, 2016 after the Court
granted one extension request.
2. This is League City’s second request for an extension of time for
filing its reply brief as appellant.
3. League City respectfully requests a 21-day extension of time for filing
its reply brief as appellant. With the extension, League City’s reply brief as
appellant will be due on Wednesday, January 20, 2016.
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4. An extension is necessary and warranted because counsel has been
required to attend to other time-sensitive matters, including the following:
a. Preparation of respondent’s brief on the merits in No. 14-0721; USAA
Texas Lloyd’s Company v. Gail Menchaca; in the Supreme Court of
Texas, filed November 20, 2015.
b. Preparation of motion for rehearing in No. 01-14-00278-CV; John
Davis d/b/a J. D. House of Style v. National Lloyds Insurance
Company; in the First Court of Appeals, Houston, Texas, filed
November 27, 2015.
c. Preparation for hearing on motion for final decree in No. 2014-30215;
In the Matter of the Marriage of Evangelina Lopez Guzman Zaragoza
and Miguel Zaragoza Fuentes, et al.; in the 245th District Court,
Harris County, Texas; held December 14, 2015.
d. Preparation for hearing on motion for entry of judgment in No. 2013-
61098; Scott D. Martin and SKM Partnership, Ltd. v. Andrews Kurth
LLP; in the 234th District Court, Harris County, Texas; held
December 14, 2015.
e. Preparation of response to claimant’s objections to continued service
of arbitrator in Arbitration No. 01-14-0001-3289; Amy Rozell, et al. v.
Richard Pohil, M.D., et al.; in the Arbitration Tribunals of the
American Arbitration Association; filed December 18, 2015.
f. Preparation of cross-respondent’s brief on the merits in No. 14-1028;
Sun Development, L.P. v. Larry Hughes and Susan Hughes; in the
Supreme Court of Texas, due December 28, 2015.
g. Preparation of response to petition for review in No. 15-0642, Estate
of Alfredo M. Pagayon, Deceased and Delia Pagayon, et al. v. Exxon
Mobil Corporation; in the Supreme Court of Texas, due January 4,
2016.
h. Preparation of petitioner’s reply brief on the merits in No. 14-1028;
Sun Development, L.P. v. Larry Hughes and Susan Hughes; in the
Supreme Court of Texas, due January 12, 2016.
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i. Preparation of brief of appellant in No. 14-15-00702-CV; Shabahram
Yazdani-Beioky v. Abdee Sharifan; in the Fourteenth Court of
Appeals, Houston, Texas, due January 13, 2016.
j. Preparation of real-party-in-interest’s brief on the merits in No. 15-
0452; In re National Lloyds Insurance Company; in the Supreme
Court of Texas, due January 27, 2015.
5. Counsel for appellant has conferred with counsel for appellee, Dale
Wainwright, and TWIA is unopposed to the requested extension.
6. This request is not sought for delay, but in order that justice may be
done. See TEX. R. APP. P. 10.5(b)(1)(C).
PRAYER
Appellant, League City, asks this Court to grant an extension of 21 days,
until Wednesday, January 20, 2016, to file its reply brief as appellant. League City
also prays for any other relief to which it may be entitled.
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Respectfully Submitted:
THE MOSTYN LAW FIRM HOGAN & HOGAN
Gregory F. Cox By: /s/ Jennifer Bruch Hogan
State Bar No. 00793561 Jennifer Bruch Hogan
gfcox@mostynlaw.com State Bar No. 03239100
6280 Delaware Street jhogan@hoganfirm.com
Beaumont, Texas 77706 Richard P. Hogan, Jr.
409.832.2777–telephone State Bar No. 09802010
409.832.2703–facsimile rhogan@hoganfirm.com
James C. Marrow
THE MOSTYN LAW FIRM State Bar No. 24013103
jmarrow@hoganfirm.com
Rene M. Sigman Pennzoil Place
State Bar No. 24037492 711 Louisiana, Suite 500
rmsigman@mostynlaw.com Houston, Texas 77002-2721
3810 W. Alabama 713.222.8800–telephone
Houston, Texas 77027 713.222.8810–facsimile
713.861.6616–telephone
713.861.8084–facsimile
Attorneys for Appellant
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CERTIFICATE OF CONFERENCE
Counsel for appellant has conferred with counsel for appellee, Dale
Wainwright, and TWIA is unopposed to the motion for extension of time to file
League City’s reply brief as appellant.
/s/ Jennifer Bruch Hogan
Jennifer Bruch Hogan
Dated: December 22, 2015
48620_1 5
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above and foregoing was
forwarded to all counsel of record by the Electronic Filing Service Provider, if
registered; a true and correct copy of this document was forwarded to all counsel
of record not registered with an Electronic Filing Service Provider and to all other
parties as follows:
Counsel for Texas Windstorm Insurance Association:
Dale Wainwright
BRACEWELL & GIULIANI LLP
111 Congress Avenue Suite 2300
Austin, Texas 78701-4061
Via TexFile
Andrew T. McKinney IV
LITCHFIELD CAVO LLP
One Riverway, Suite 1000
Houston, Texas 77056
Via TexFile
James R. Old, Jr.
JAY OLD & ASSOCIATES, PLLC
3560 Delaware, Suite 308
Beaumont, Texas 77706
Via TexFile
/s/ Jennifer Bruch Hogan
Jennifer Bruch Hogan
Dated: December 22, 2015
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