the City of Austin v. Jennifer Frame, Individually, and as Personal Representative of the Estate of John William Griffith Greg Griffith Cheryl Burris And Diana Pulido

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ACCEPTED 03-15-00292-CV 6006954 THIRD COURT OF APPEALS AUSTIN, TEXAS 7/9/2015 4:52:35 PM JEFFREY D. KYLE CLERK No. 03-15-00292-CV FILED IN 3rd COURT OF APPEALS In the Third Court of Appeals AUSTIN, TEXAS 7/9/2015 4:52:35 PM Austin, Texas JEFFREY D. KYLE Clerk THE CITY OF AUSTIN Appellant V. JENNIFER FRAME, INDIVIDUALLY, AND AS PERSONAL REPRESENTATIVE OF THE ESTATE OF JOHN WILLIAM GRIFFITH, GREG GRIFFITH, CHERYL BURRIS AND DIANA PULIDO Appellee APPEAL FROM CAUSE NO. D-1-GN-12-003557 RD 53 JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ RESPONSE BRIEF Sean E. Breen Mike Davis State Bar No. 00783715 State Bar No. 05549500 HOWRY BREEN & HERMAN, L.L.P. SLACK & DAVIS, L.L.P. 1900 Pearl Street 2705 Bee Cave Road, Suite 220 Austin, Texas 78705 Austin, Texas 78746 Telephone (512) 474-7300 Telephone (512) 795-8686 Facsimile (512) 474-8557(fax) Facsimile (512) 795-8787 sbreen@howrybreen.com mdavis@slackdavis.com ATTORNEYS FOR APPELLEES APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF COME NOW Appellees, Jennifer Frame, Individually, and as Personal Representative of the Estate of John William Griffith, Greg Griffith, Cheryl Burris and Diana Pulido and files this Unopposed Motion for Extension of Time to File Appellees’ Response Brief and in support thereof, would show as follows: 1. The current deadline for filing Appellees’ Response Brief is July 13, 2015. 2. Appellees seek a thirty-day extension to file their brief, making the brief due on or before August 12, 2015. 3. The undersigned counsel has been heavily involved in numerous highly complex matters in Federal and State Court, which necessitate this request. This request is not for delay only. 4. This is the first request to extend the deadline for Appellees’ response brief. 5. Counsel has conferred with Counsel for Appellant and she has no objection and indicates the motion is unopposed. WHEREFORE, Appellees respectfully ask the Court to grant the Motion to Extend Time to File Appellees’ Response Brief so that Appellees’ response is due on August 12, 2015 and to grant such other relief to which they may be entitled. 2 Respectfully submitted, /s/ Sean E. Breen Sean E. Breen State Bar No. 00783715 HOWRY BREEN & HERMAN, L.L.P. 1900 Pearl Street Austin, Texas 78705 (512) 474-7300 (512) 474-8557(fax) sbreen@howrybreen.com Mike Davis State Bar No. 05549500 mdavis@slackdavis.com SLACK & DAVIS, L.L.P. 2705 Bee Cave Road, Suite 220 Austin, Texas 78746 Telephone: (512) 795-8686 Facsimile: (512) 795-8787 Counsel for Appellee CERTIFICATE OF CONFERENCE I hereby certify that on July 9, 2015 I conferred with Counsel for Appellant regarding this motion and she does not oppose this motion. /s/ Sean E. Breen Sean E. Breen 3 CERTIFICATE OF SERVICE This is to certify that I have served a copy of the foregoing on all parties, or their attorneys of record, in compliance with the Appellate Rules of Civil Procedure, this 9th day of July, 2015. Chris Edwards Assistant City Attorney State Bar No. 00789276 chris.edwards@austintexas.gov City of Austin - Law Department P.O. Box 1546 Austin, Texas 78767-1546 Telephone (512) 974-2419 Facsimile (512) 974-1311 /s/ Sean E. Breen Sean E. Breen 4