ACCEPTED
14-18-00174-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
5/14/2018 9:59 AM
CHRISTOPHER PRINE
CLERK
No. 14-18-00174-CV
IN THE COURT OF APPEALS FILED IN
14th COURT OF APPEALS
FOR THE FOURTEENTH DISTRICT OF TEXAS HOUSTON, TEXAS
AT HOUSTON 5/14/2018 9:59:58 AM
CHRISTOPHER A. PRINE
Clerk
SAN JACINTO RIVER AUTHORITY,
Appellant,
V.
RODRICK DENNIS, ET AL.,
Appellees.
On Appeal from the 125th Judicial District Court of Harris County, Texas,
Trial Court Cause No. 2017-74341
UNOPPOSED FIRST MOTION FOR EXTENSION OF
TIME TO FILE BRIEF OF APPELLEES
TO THE HONORABLE COURT OF APPEALS:
Appellees respectfully file this unopposed first motion for a 30-day
extension of time to file their brief.
1. The present deadline for filing the appellees’ brief is May 14, 2018.
2. Appellees seek a 30-day extension to file their brief, until June 13,
2018.
3. This is Appellees’ first request for an extension of time to file their
brief.
4. This motion is unopposed.
5. The following grounds provide “good cause” for extending the time to
file the brief. Lead appellate counsel, Russell Post, has been and continues to be
engaged in other litigation with imminent deadlines that will prevent him from
completing the brief before the present deadline, including, but not limited to, the
following:
• Preparation of brief of appellees in No. 03-17-00722-CV; Raymond
Boytim, et al. v. Brigham Exploration Company, et al.; In the Third
Court of Appeals. This brief was filed on May 2, 2018.
• Assistance with preparation of reply brief in No. 14-18-00094-CV and
14-18-00095-CV; Elaine T. Marshall, et al. v. Preston Marshall; In
the Fourteenth Court of Appeals. The brief is due to be filed on or
before May 23, 2018, after one extension.
• Preparation of brief of appellees in No. 17-51089; William Parrish, et
al. v. Premier Directional Drilling, L.P.; In the Fifth Circuit Court of
Appeals. The brief is due to be filed on or before May 24, 2018.
• Preparation of reply brief in No. 17-20545; Environment Texas
Citizen Lobby Incorporated, et al. v. ExxonMobil Corporation, et al.;
In the Fifth Circuit Court of Appeals. The reply brief is due to be
filed on or before May 25, 2018, after three extensions.
• Preparation of brief of appellant in No. 14-17-00791-CV; Equistar
Chemicals, LP v. ClydeUnion DB, Limited; In the Fourteenth Court of
Appeals. This brief in a complex commercial appeal is due to be filed
on or before May 25, 2018, after three extensions.
• Preparation of brief on the merits in No. 17-0814; Helix Energy
Solutions Group, Inc. et al. v. BH Contractors, LLC; In the Supreme
Court of Texas. The brief is due on or before May 30, 2018, after one
extension.
6. This motion is not filed for the purpose of delay, but to allow counsel
adequate time to prepare the brief.
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For these reasons, Appellees respectfully request an extension of time to file
their brief until June 13, 2018.
Respectfully submitted,
BECK REDDEN LLP
By:/s/ Russell S. Post
Russell S. Post
State Bar No. 00797258
rpost@beckredden.com
Kyle Lawrence
State Bar No. 24087895
klawrence@beckredden.com
1221 McKinney, Suite 4500
Houston, TX 77010-2010
(713) 951-3700
(713) 951-3720 – Fax
ATTORNEYS FOR APPELLEES,
RODRICK DENNIS, ET AL.
CERTIFICATE OF CONFERENCE
I certify that Appellees’ counsel has conferred with counsel for Appellant,
and Appellant does not oppose the requested extension.
/s/ Russell S. Post
Russell S. Post
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CERTIFICATE OF SERVICE
I hereby certify that on May 14, 2018, a true and correct copy of the above
and foregoing document was forwarded to all counsel of record via the Electronic
Service Provider pursuant to the Texas Rules of Appellant Procedure as follows:
William S. Helfand
bill.helfand@lewisbrisbois.com
Shane L. Kotlarsky
shane.kotlarsky@lewisbrisbois.com
Lewis Brisbois Bisgaard & Smith
24 Greenway Plaza, Suite 1400
Houston, TX 77046
Attorneys for Appellant, San Jacinto River Authority
/s/ Russell S. Post
Russell S. Post
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