ACCEPTED
03-15-00377-CV
6368348
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/5/2015 1:59:07 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00377-CV
FILED IN
IN THE COURT OF APPEALS FOR THE AUSTIN,OF
3rd COURT APPEALS
TEXAS
THIRD JUDICIAL DISTRICT OF TEXAS8/5/2015 1:59:07 PM
AT AUSTIN, TEXAS JEFFREY D. KYLE
Clerk
CITY OF LEANDER, et al.,
Appellants – Defendants,
V.
PREMAS GLOBAL LEANDER I, LLC,
Appellee – Plaintiff.
Appeal from the 277th Judicial District Court of Williamson County, Texas
Cause No. 15-0088-C277
APPELLEE’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSE BRIEF
Appellee Premas Global Leander I, LLC (Premas) files this unopposed motion
for extension of time to file its response brief, and in support therefore would
respectfully show as follows:
1. The current deadline for Premas to file its response brief is August 10,
2015.
2. Premas seeks a 21-day extension to file its response brief, making its
brief due on or before August 31, 2015.
3. Counsel for Premas 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 Premas’s positions and arguments may be fully developed and presented
to this Court in a concise and persuasive fashion.
4. This is the first request to extend the deadline for Premas’s response
brief.
5. Counsel for Premas has conferred with Counsel for Appellants, who
indicated he is unopposed to Premas’s request for an extension of time to file its
response brief.
WHEREFORE, PREMISES CONSIDERED, Premas respectfully requests an
order granting its Unopposed Motion for Extension of Time to File Response Brief
so that Premas’s response brief is due on or before August 31, 2015, and for such
other and further relief to which it may be entitled.
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Dated: August 5, 2015 Respectfully submitted,
HOWRY BREEN & HERMAN, LLP
_______________________________
Sean E. Breen
State Bar No. 00783715
sbreen@howrybreen.com
Randy R. Howry
State Bar No. 10121690
rhowry@howrybreen.com
James Hatchitt
State Bar No. 24072478
jhatchitt@howrybreen.com
1900 Pearl Street
Austin, Texas 78705-5408
Tel. (512) 474-7300
Fax (512) 474-8557
Attorneys for Plaintiff – Appellee
Premas Global Leander I, LLC
CERTIFICATE OF CONFERENCE
I hereby certify that on August 5, 2015, I conferred with Counsel for Appellants by
e-mail regarding the relief sought by this motion, and he indicated the motion is
unopposed.
Sean E. Breen
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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.
Bradford E. Bullock Electronic service
bradford@cityattorneytexas.com □ In person
KNIGHT & PARTNERS □ Registered mail, return receipt requested
Executive Office Terrace □ Commercial delivery service
223 West Anderson Lane, Suite A- □ Facsimile
105 Electronic mail
Austin, Texas 78752
Tel. (512) 323-5778
Fax (512) 323-5773
Attorney for Defendants – Appellants
City of Leander, Kent Cagle, and
Thomas Yantis
Sean E. Breen
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