Manor Independent School District v. Deydra Steans

ACCEPTED 03-15-00294-CV 5431844 THIRD COURT OF APPEALS AUSTIN, TEXAS 5/27/2015 12:12:05 PM JEFFREY D. KYLE CLERK CAUSE NO. D-1-GN-13-000241 DEYDRA STEANS § IN THE DISTRICT COURT Petitioner § FILED IN 3rd COURT OF APPEALS § AUSTIN, TEXAS V. § OF TRAVIS COUNTY, TEXAS 5/27/2015 12:12:05 PM § JEFFREY D. KYLE MANOR INDEPENDENT § Clerk SCHOOL DISTRICT § Defendant § § § 200th JUDICIAL DISTRICT APPELLEE’S MOTION TO EXTEND TIME TO FILE RESPONSE TO APPELLANT’S MOTION TO STAY Appellee Deydra Steans asks the court to extend the time to file her brief. A. Introduction 1. Appellant is Manor Independent School District. 2. Appellee is Deydra Steans. 3. The deadline to file this response is May 26, 2015. 4. The parties have agreed to this motion. B. Argument and Authorities 5. The Court has authority under TRAP 55.7 and 10.5 to extend the time to file the brief. 6. Appellee requests an additional 30 days to file her brief. 7. No extension has been granted to extend the time to file Appellee’s brief. 8. Appellant needs additional time because the parties have engaged in settlement negotiations and the parties believe the matter has settled. A preliminary mediator proposal has been approved by both sides and the parties are attempting to finalize a settlement agreement. C. Conclusion 9. Because the parties have resolved the matter and need time to finalize a settlement it is necessary to extend the time for the response to the outstanding motion. D. Prayer 10. For these reasons Appellee asks the Court to grant an extension of time to file her brief until June 26th, 2015. Respectfully submitted, POTTER BLEDSOE, LLP By: /s/ Gary L. Bledsoe Gary L. Bledsoe State Bar No. 02476500 gbledsoe@potterbledsoe.com Harry G. Potter III hpotter@potterbledsoe.com State Bar No. 16175300 Alondra Johnson ajohnson@potterbledsoe.com State Bar No. 24087801 316 W. 12th Street Austin, Texas 78701 (512) 322-9992 Telephone (512) 322-0840 Fax CERTIFICATE OF CONFERENCE I certify that I have conferred with Jennifer Powell by telephone and e-mail and she has agreed and is unopposed to Appellee’s Motion to Extend Time to File A Response to Appellant’s Motion to Stay. /s/ Gary L. Bledsoe Gary Bledsoe CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been forwarded to the following parties via e-mail/e-service, United States certified mail and/or via facsimile on this 26th day of May 2015. Jennifer A. Powell Eichelbaum, Wardell, Hansen, Powell & Mehl, P.C. 4201 Parmer Lane, Suite A100 Austin, Texas 78727 512/476-9944 512/472-2599 fax jpowell@edlaw.com cc:nbn@edlaw.com Attorneys for Defendant /s/ Gary L. Bledsoe Gary Bledsoe