Shayn a Proler v. City of Houston

ACCEPTED
14-15-00387-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/13/2015 1:51:53 PM
CHRISTOPHER PRINE
CLERK

No. 14-15-00387-CV
_______________________________________________
FILED IN
14th COURT OF APPEALS
In the Court of Appeals for the HOUSTON, TEXAS
Fourteenth District of Texas at Houston 11/13/2015 1:51:53 PM
_______________________________________________CHRISTOPHER A. PRINE
Clerk

SHAYN A. PROLER
Appellants
V.

CITY OF HOUSTON,
Appellee
_______________________________________________

On Appeal from the 234th Judicial District Court
Harris County, Texas
Trial Court Case No. 2007-30944
______________________________________________________________

Unopposed Motion for Extension of Time
to File Appellee’s Brief
______________________________________________________________

TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Appellee respectfully requests a thirty-day extension of time to file its
Appellee’s Brief, up to and including December 16, 2015, and in support
respectfully shows as follows:

1. Appellant’s Brief was filed October 16, 2015, generating a due date for
Appellee’s Brief of November 16, 2015.

2. This is the first motion for an extension of time to file the brief. It is
unopposed.

3. The undersigned has a busy appellate practice, including related trial
court motions and hearings, with the City. Among other briefs the
 undersigned has been, and continues to be, working on during this
briefing period are:

a. No. 15-20237, Ricardo Salazar-Limon v. City of Houston, et al., in the
United States Court of Appeals for the 5th Circuit, Appellees’ Brief
due November 18, 2015;
b. In re City of Houston, No. 15-_____, in the Supreme Court of Texas,
anticipated filing date November 23, 2015.

4. The undersigned has conferred with the attorney for Appellant and he
does not oppose the extension.

5. This motion is not for delay but so that justice may be done.

For these reasons, Appellee respectfully asks that the Court grant it a

thirty-day extension of time to file its brief, and grant any other relief to which

it is entitled.
 Respectfully submitted,

DONNA L. EDMUNDSON
City Attorney
JUDITH L. RAMSEY
Chief, General Litigation Section

By: /s/ Robert W. Higgason
Robert W. Higgason
Senior Assistant City Attorney
State Bar No. 09590800
City of Houston Legal Department
900 Bagby, 3rd Floor
Houston, Texas 77002
Telephone: 832.393.6481
Facsimile: 832.393.6259
robert.higgason@houstontx.gov

Attorneys for Appellee

Certificate of Conference

I hereby certify that I have conferred with Appellant’s counsel and that
Appellant is unopposed to this motion.

/s/ Robert W. Higgason
Robert W. Higgason
 Certificate of Service

I hereby certify that on November 13, 2015, a true and correct copy of
the foregoing has been served on counsel below via e-service.

David T. Lopez
DAVID T. LOPEZ & ASSOC.
3900 Montrose Blvd.
Houston, Texas 77006-4959
dtlopez@lopezlawfirm.com

Attorney for Appellant
/s/ Robert W. Higgason
Robert W. Higgason