NHH-Canal Street Apartments, Inc., a Texas Non-Profit Corporation v. Harris County Appraisal District and Harris County Appraisal District Appraisal Review Board

ACCEPTED
14-14-00251-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/25/2015 12:03:02 PM
CHRISTOPHER PRINE
CLERK

NO. 14-14-00251-CV
__________________________________________________________________
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FOURTEENTH DISTRICT OF TEXAS 11/25/2015 12:03:02 PM
AT HOUSTON, TEXAS CHRISTOPHER A. PRINE
Clerk
__________________________________________________________________

NHH-CANAL STREET APARTMENTS, INC.,
A TEXAS NON-PROFIT CORPORATION
Appellant
V.

HARRIS COUNTY APPRAISAL DISTRICT AND
HARRIS COUNTY APPRAISAL DISTRICT APPRAISAL REVIEW
BOARD
Appellees
__________________________________________________________________

On Appeal from the 295TH Judicial District Court of Harris County, Texas;
Cause No. 2010-68486
Honorable Caroline E. Baker, Presiding

MOTION TO EXTEND TIME TO FILE
APPELLEE’S MOTION FOR REHEARING

TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Pursuant to Rules 10.5(b) and 49.8 of the Texas Rules of Appellate Procedure,

Appellee, Harris County Appraisal District, files this Motion to Extend Time to File

Appellee’s Motion for Rehearing, and in support thereof would respectfully show the

following:
 A. Appellee’s Motion for Rehearing is due to be filed on or before Friday,

December 4, 2015.

B. Appellee requests a 7 day extension of time to file its brief, which, if

granted, would make the brief due on or before Friday, December 11,

2015.

C. The undersigned will be traveling for the Thanksgiving holiday, as will

other attorneys in this firm who have worked on the case. In addition,

some constituents of the Appellee are unavailable due to the holiday.

D. This extension is requested not for delay, but in order to allow

Appellee’s counsel sufficient time to complete the motion.

E. This is Appellee’s first request for an extension of time to file this

Motion for Rehearing.

F. Counsel for Appellant has been contacted and is not opposed to this

request, as set forth in the certificate of conference.

WHEREFORE, PREMISES CONSIDERED, Appellee respectfully requests

that this Court grant this Motion to Extend Time for Filing Appellee’s Motion for

Rehearing and set the deadline for filing the motion on Friday, December 11, 2015.

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 Respectfully submitted,

OLSON & OLSON, L.L.P.

By: /s/ Eric C. Farrar
Eric C. Farrar
State Bar No. 24036549
efarrar@olsonllp.com
Wortham Tower, Suite 600
2727 Allen Parkway
Houston, Texas 77019
(713) 533-3800 – Phone
(713) 533-3888 – Fax
ATTORNEYS FOR APPELLEE
HARRIS COUNTY APPRAISAL
DISTRICT

CERTIFICATE OF CONFERENCE

Appellee’s counsel contacted counsel for Appellant on November 24, 2015,

and counsel is unopposed to this request to extend time for Appellee to file its Motion

for Rehearing.

/s/ Eric C. Farrar
Eric C. Farrar

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 CERTIFICATE OF SERVICE

I hereby certify that on November 24, 2015 a true and correct copy of the

foregoing Motion to Extend Time to File Appellee’s Motion for Rehearing was

served via:

J. Eric Pardue  CMRRR #
Pat Mizell  Facsimile No. (713) 758-2346
Glen Rosenbaum  Hand Delivery
Vinson & Elkins, LLP  U.S.P.S.
1001 Fannin Street, Suite 2500  E-mail:
Houston, Texas 77002-6760  E-Service

Gwen J. Samora  CMRRR #
The Samora Law Firm  Facsimile No.
4210 Oberlin Street  Hand Delivery
Houston, Texas 77005  U.S.P.S.
 E-mail:
 E-Service

/s/ Eric C. Farrar
Eric C. Farrar

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