Steve Griffith, in His Official Capacity, Douglas Brinkley, in His Offiicial Capacity, Scott Schultz in His Official Capacity, and Mark Grothaus, in His Official Capacity v. Collision Clinic, L.L.C. and Hanna "John" Elias

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ACCEPTED 14-14-00900-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/17/2015 4:54:42 PM CHRISTOPHER PRINE CLERK NO. 14-14-00900-CVV IN THE FOURTEENTH COURT OF APPEALS FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 2/17/2015 4:54:42 PM CHRISTOPHER A. PRINE Steve Griffith in his Official Capacity, Douglas Brinkley in his OfficialClerk Capacity, Scott Schultz in his Official Capacity, and Mark Grothaus in his Official Capacity, Appellants, v. Collision Clinic, L.L.P. and Hanna “John” Elias, Appellees. APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ RESPONSE BRIEF COME NOW, Collision Clinic, L.L.C. and Hanna “John” Elias, Appellees herein, and move the Court for an extension of time to file Appellees’ Response Brief in this cause, and in support thereof would show the Court as follows: I. This is an interlocutory appeal on an order denying a plea to the jurisdiction pursuant to §51.014(a)(5) and (8), Tex. Civ. Prac. & Rem. Code. Appellants filed their brief on or about January 21, 2015. Subsequently, a supplemental clerks record was filed January 29, 2015. Appellees’ brief in response was due February 10, 2015. II. This is Appellees’ first request for an extension of time to file Appellees’ 1 Brief. III. Appellees hereby request a three week extension of time to file Appellees’ Response Brief until the 3rd day of March 2015, and as reasons therefore would show the Court as follows: The undersigned counsel has been in numerous depositions and hearings and has had numerous briefs due in other matters in the last thirty days and therefore has not been able to devote sufficient amount of time to the review of this entire record and the preparation of the brief. In addition, the City of Sugar Land recently adopted a resolution related to the underlying issue in the present lawsuit and counsel for Appellees have needed time to analyze the impact of the resolution on the present litigation. IV. Appellees have advised counsel for Appellants of their intent to file this Motion for Extension of Time and requested they advise whether they are opposed or unopposed. At the time of this filing, counsel for Appellees have not received a response to their request. WHEREFORE, PREMISES CONSIDERED, the undersigned counsel respectfully prays that this Honorable Court extend the time for filing the Appellees= 2 Response Brief in this cause until the 3rd day of March, 2015. Respectfully submitted, THE IRWIN LAW FIRM, P.C. By: /s/ Leland M. Irwin Leland M. Irwin State Bar No. 00790945 leland@irwin-lawfirm.com 210 Morton Street Richmond, Texas 77469 (832) 847-4111 Facsimile (832) 847-4177 -AND- YOUNG AND HUSAIN, P.L.L.C. By: /s/ Omar Khawaja Omar Khawaja State Bar No. 24072181 okhawaja@yhlawfirm.com 2700 Post Oak Blvd., Suite 1220 Houston, Texas 77056 713-621-8900 Facsimile 713-621-8909 ATTORNEYS FOR REAL PARTIES IN INTEREST COLLISION CLINIC, L.L.C. AND HANNA “JOHN” ELIAS 3 VERIFICATION STATE OF TEXAS § § COUNTY OF FORT BEND § BEFORE ME, the undersigned Notary Public, on this day personally appeared, Leland M. Irwin, who being by me duly sworn on his oath deposed and said that he is the attorney for Collision Clinic, L.L.C. and Hanna "John" Elias, Appellees in the above-entitled and numbered cause; that he has read the above and foregoing Motion For Extension of Time to File Appellees' Response Brief; and that every statement contained therein is within h. owledge and is true and correct. SHERRIE MONTGOMERY MY COMMISSION EXPIRES March 9, 2015 Notary Public in and for the State of Texas CERTIFICATE OF CONFERENCE This is to certify that on February 17, 2015, I have attempted to confer with Patricia L. Hayden, counsel for Appellants, via email regarding this Motion for Extension of Time to File Appellees' Response Brief, and that she has not responded to my request. Isl Leland M Irwin Leland M. Irwin 4 CERTIFICATE OF SERVICE I hereby certify that on February 17, 2015, a true and correct copy of this document was served on the following counsel and respondent: E-serve and Email: PHayden@OlsonLLP.com Patricia L. Hayden Olson & Olson, L.L.P. 209 e. Mulberry, Suite 100 Angleton, Texas 77515 Attorney for Defendants Steve Griffith, Douglas Brinkley, Scott Schultz, and Mark Grothaus E-Serve and Email: don@dontschwartzlaw.com Don T. Schwartz Schwartz & Kalinowski, L.L.P. 1821 Mons Avenue Rosenberg, TX 77471 Attorney for Defendant A & M Wrecker Service Facsimile 281/238-8514 And Email: mcdougal-law-larry@comcast.net Larry P. McDougal 809 Houston St. Richmond, TX 77469 Attorney for Defendant J&H Towing and Recovery Facsimile 713/802-1339 5 Dan Reiver 1445 North Loop West, Suite 900 Houston, TX 77008 Attorney for Defendant Long’ Towing, LLC Facsimile 281/250-4253 Francisco R. Yeverino 112 W. 4th Street Houston, TX 77007 Attorney for Defendant Big Rod’s Towing, Inc. Facsimile 713/789-7703 Daniel F. Castaneda Buckley, White, Castaneda & Howell, L.L.P. 2401 Fountainview, Suite 1000 Houston, Texas 77057 Attorney for Defendant Russell Rossett and Hadjes, Inc. /s/ Leland M. Irwin Leland M. Irwin 6