City of Leander Kent Cagle, Individually and in His Official Capacity as City Manager of the City of Leander and Thomas Yantis, Individually and in His Official Capacity as Assistant City Manager and Planning Director for the City of Leander v. Premas Global Leander I, LLC

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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. -2- 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 -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. 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 -4-