the Harris County Appraisal District v. Clear Lake Office Partners, LLC and Metro Clear Lake Office Partners, LLC

ACCEPTED
14-15-00150-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
3/26/2015 12:39:07 PM
CHRISTOPHER PRINE
CLERK

NO. 14-15-00150-CV
__________________________________________________________________
FILED IN
14th COURT OF APPEALS
IN THE HOUSTON, TEXAS
COURT OF APPEALS 3/26/2015 12:39:07 PM
FOURTEENTH DISTRICT OF TEXAS CHRISTOPHER A. PRINE
HOUSTON, TEXAS Clerk
__________________________________________________________________

HARRIS COUNTY APPRAISAL DISTRICT,
Appellant
V.

CLEAR LAKE OFFICE PARTNERS, LLC AND
METRO CLEARK LAKE OFFICE PARTNERS, LLC,

Appellees
__________________________________________________________________

On Appeal from the 127th Judicial District Court of Harris County, Texas
Trial Court Cause No. 2013-53295

APPELLANT’S UNOPPOSED MOTION
TO EXTEND TIME TO FILE THE CLERK’S RECORD

TO THE HONORABLE FIRST COURT OF APPEALS:

Pursuant to Rule 10.5(b) of the Texas Rules of Appellate Procedure,

Appellant, HARRIS COUNTY APPRAISAL DISTRICT files this Unopposed

Motion to Extend the Time to File the Clerk’s Record, and in support thereof would

respectfully show the following:

A. The Clerk’s Record was due to be filed on or before March 23, 2015.
 B. Appellant requests a forty-six (46) day extension of time to file the

Clerk’s Record, which, if granted, would make the record due on or

before Monday, May 11, 2015.

C. Good cause exists for this extension because the parties have

tentatively settled this case, subject to approval of the Board of

Directors of the Harris County Appraisal District (“Board”).

Approval by the Board is required because Appellant is a

governmental entity. In addition the Texas Property Tax Code

requires a judgment in order to effectuate the settlement. Tex. Tax

Code Ann. § 25.25(a) (West, Westlaw through 2013 sess.). Upon

approval by the Board, the parties will submit a motion to remand for

entry of an agreed final judgment.

D. This is Appellant’s first request for an extension of time to file the

Clerk’s Record. No further request for an extension will be made,

absent compelling circumstances.

E. Counsel for Appellees has been contacted and is not opposed to this

request, as set forth in the certificate of conference.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays that

this Court grant this Unopposed Motion to Extend Time to File the Clerk’s Record

and set the deadline for filing the record on May 11, 2015.

Clear Lake Office 14-15-00150-CV 2
HCAD’s Motion to Extend Time to File Clerk’s Record
 Respectfully submitted,

OLSON & OLSON, L.L.P.

By: /s/ Robert P. McConnell
Robert P. McConnell
State Bar No. 13448300
rmcconnell@olsonllp.com
David W. Olson
State Bar No. 24051136
dolson@olsonllp.com
Wortham Tower, Suite 600
2727 Allen Parkway
Houston, Texas 77019
Telephone: (713) 533-3800
Facsimile: (713) 533-3888

ATTORNEYS FOR APPELLANT

CERTIFICATE OF CONFERENCE

Appellant’s counsel contacted Appellees’ counsel regarding this matter and
she is unopposed.

/s/ Robert P. McConnell
Robert P. McConnell

Clear Lake Office 14-15-00150-CV 3
HCAD’s Motion to Extend Time to File Clerk’s Record
 CERTIFICATE OF SERVICE

I hereby certify that on the 26th day of March 2015, a true and correct copy

of the foregoing Appellant’s Unopposed Motion to Extend Time to File the Clerk’s

Record was served on the counsel for Appellees by:

telecopy (713) 688-0199

certified mail, return receipt requested

electronic service

to Mary A. Van Kerrebrook, VAN KERREBROOK & ASSOCIATES P.C., 712

Main Street, Suite 720, Houston, Texas 77002.

/s/ Robert P. McConnell
Robert P. McConnell

Clear Lake Office 14-15-00150-CV 4
HCAD’s Motion to Extend Time to File Clerk’s Record