April Brown, David Rafferty, Steve Gann, Kathy Hilton, Irene Garcia and Steve Stuckey v. William Hensley, Tom Jenkins, Troy Jones, David Marks, Barnard Pearl, Thomas Walsh, Stan Williams, Jack Ereira and Andrew Rosenberg
ACCEPTED
14-14-00981-cv
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
6/9/2015 12:00:34 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS
FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS
AT HOUSTON FILED IN
14th COURT OF APPEALS
______________________________________________________
HOUSTON, TEXAS
6/9/2015 12:00:34 PM
No. 14-14-00981-CV CHRISTOPHER A. PRINE
Clerk
_______________________________________________________
DAVID RAFFERTY, STEVE GANN, KATHY HILTON, IRENE GARCIA,
STEVE STUCKEY and APRIL BROWN
Appellants,
v.
THE LANDING COUNSEL OF CO-OWNERS, ET AL.
Appellees.
__________________________________________________________________
On Appeal from the 127th Judicial District Court of Harris County, Texas
Trial Court Cause No. 2010-56653-B
__________________________________________________________________
THIRD AGREED MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ BRIEF
TO THE HONORABLE JUDGE OF THIS COURT:
COME NOW, April Brown, David Rafferty, Steve Gann, Kathy Hilton,
Irene Garcia and Steve Stuckey (hereinafter “Appellants”) in the above-referenced
matter and file this Second Agreed Motion for Extension of Time to File
Appellants’ Brief and, as such, will show as follows:
1. Appellants’ Brief was originally due to be filed with this Court on
April 13, 2015. This Court granted an extension, making the Brief due on May 13,
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2015 and another extension making it due on June 12, 2015. Appellants seek an
additional 30 day extension, making Appellants’ Brief due on July 13, 2015.
2. The undersigned is lead counsel in a matter that is going before the
Planning Commission in San Antonio on June 10, 2015. Additionally, Counsel has
a trial scheduled for the docket beginning June 15, 2015 in Harris County District
Court. The case is third on the docket, so it is likely to get reached. As such,
Counsel has spent this week preparing for trial. As a result of this, Counsel has
been unable to give significant attention to this matter. Accordingly, due to these
matters and other pending trial court matters that require immediate attention of
counsel, Appellants request a thirty day extension of its June 12 Brief deadline.
3. Appellants do not seek this extension merely for the sake of seeking a
delay in the proceedings. To the contrary, Appellants are simply asking for some
additional time to so that counsel has sufficient time to research, draft and file their
Brief. The undersigned has conferred with counsel for Appellees in this matter and
she has indicated that they are unopposed to this Motion.
PRAYER
Appellants respectfully request that the Court grant their Unopposed Motion
for Extension of Time to File Appellants’ Brief and extend the June 13 deadline by
thirty (30) days.
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Respectfully Submitted,
Andy Taylor & Associates, P.C.
BY: /s/Andy Taylor
Andy Taylor
State Bar No. 19727600
2668 Highway 36 S, #288
Brenham, Texas 77833
713-222-1817 (telephone)
713-222-1855 (facsimile)
CERTIFICATE OF SERVICE
I certify that on June 9, 2015, I conferred with Shelley White, counsel for
Appellees, in this matter and he indicated that he is unopposed to the relief sought
in this motion.
/s/ Amanda Peterson
Amanda Peterson
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was
served via electronic service to the following counsel of record on June 9, 2015.
Shelley White, Henry Platts, Jr., Howard Close, 713-572-4320
Tod Phillips, Patrick McAndrew
/s/ Andy Taylor
Andy Taylor
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