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 6367541 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/5/2015 1:37:11 PM JEFFREY D. KYLE CLERK No. 03-15-00292-CV FILED IN IN THE COURT OF APPEALS FOR THE AUSTIN,OF 3rd COURT APPEALS TEXAS THIRD JUDICIAL DISTRICT OF TEXAS8/5/2015 1:37:11 PM AT AUSTIN, TEXAS JEFFREY D. KYLE Clerk CITY OF AUSTIN, Appellant – Defendant, V. JENNIFER FRAME, Individually and as Personal Representative of the Estate of John William Griffith, et al., Appellees – Plaintiffs. Appeal from the 53rd Judicial District Court of Travis County, Texas Cause No. D-1-GN-12-003557 APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF Appellees Jennifer Frame, Individually and as Personal Representative of the Estate of John William Griffith, Greg Griffith, Cheryl Burris, and Diana Pulido file this unopposed motion for extension of time to file their response brief, and in support therefore would respectfully show as follows: 1. The current deadline for Appellees to file their response brief is August 12, 2015. 2. Appellees seek a 14-day extension to file its response brief, making its brief due on or before August 26, 2015. 3. Counsel for Appellees has been heavily involved in numerous highly complex matters in both state and federal court. This request is not for delay only, but so that Appellees’ positions and arguments may be fully developed and presented to this Court in a concise and persuasive fashion. 4. This is the second request to extend the deadline for Appellees’ response brief. 5. Counsel for Appellees has conferred with Counsel for the City of Austin, who indicated she is unopposed to Appellees’ request for an extension of time to file their response brief. WHEREFORE, PREMISES CONSIDERED, Appellees respectfully request an order granting their Unopposed Motion for Extension of Time to File Response Brief so that Appellees’ response brief is due on or before August 26, 2015, and for such other and further relief to which they may be justly entitled. -2- Dated: August 5, 2015 Respectfully submitted, HOWRY BREEN & HERMAN, LLP _______________________________ Sean E. Breen State Bar No. 00783715 sbreen@howrybreen.com HOWRY BREEN & HERMAN, L.L.P. 1900 Pearl Street Austin, Texas 78705 Tel. (512) 474-7300 Fax (512) 474-8557 Mike Davis State Bar No. 05549500 mdavis@slackdavis.com SLACK & DAVIS, L.L.P. 2705 Bee Cave Road, Suite 220 Austin, Texas 78746 Tel. (512) 795-8686 Fax (512) 795-8787 Attorneys for Appellees CERTIFICATE OF CONFERENCE I hereby certify that on August 5, 2015, I conferred with Counsel for Appellant by e-mail regarding the relief sought by this motion, and she indicated the motion is unopposed. Sean E. Breen -3- CERTIFICATE OF SERVICE I certify that a true and correct copy of this document was delivered on August 5, 2015, in compliance with Rules 9.5(b) of the Texas Rules of Appellate Procedure, to the parties listed and in the manner indicated below. Chris Edwards  Electronic service Assistant City Attorney □ In person City of Austin - Law Department □ Registered mail, return receipt requested P.O. Box 1546 □ Commercial delivery service Austin, Texas 78767-1546 □ Facsimile Tel. (512) 974-2419  Electronic mail Fax (512) 974-1311 chris.edwards@austintexas.gov Attorney for Defendant – Appellant City of Austin Sean E. Breen -4-