ACCEPTED
04-15-00736-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
11/30/2015 4:47:57 PM
KEITH HOTTLE
CLERK
CAUSE NO. 04-15-00736-CV
*** FILED IN
4th COURT OF APPEALS
IN THE COURT OF APPEALS SAN ANTONIO, TEXAS
11/30/15 4:47:57 PM
FOURTH COURT OF APPEALS DISTRICT
KEITH E. HOTTLE
SAN ANTONIO, TEXAS Clerk
***
CITY OF LAREDO, TEXAS
Appellant,
V.
NORTHTOWN DEVELOPMENT, INC. & GATEWAY CENTENNIAL
DEVELOPMENT, CO. (Successors-In-Interest to Trautmann Investment
Properties, Ltd.)
Appellees
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
LAW OFFICES OF RYAN HENRY, PLLC
Ryan S. Henry
State Bar No. 24007347
Artin T. DerOhanian
State Bar No. 24095346
1380 Pantheon Way, Suite 110
San Antonio, Texas 78232
210-257-6357 (Telephone)
210-569-6494 (Facsimile)
Ryan.Henry@rshlawfirm.com
Artin.DerOhanian@rshlawfirm.com
ATTORNEYS FOR APPELLANT
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TO THE HONORABLE JUDGE OF SAID COURT:
Appellant, CITY OF LAREDO, TEXAS (hereinafter “City”), files this its
First Motion for Extension of Time to File Brief and shows the Court as follows:
The Appellant City filed this appeal on November 20, 2015 due to the judge
in the 111th District Court of Webb County denying its Plea to the Jurisdiction. The
court has listed the brief due on December 15, 2015. Due to the coming holidays
putting several business days on hold, Appellant requests a 30 day extension of the
brief deadline making the due date January 15, 2016. I have consulted with the
attorneys for the Appellees and they are unopposed to the relief sought in this motion
to extend deadline.
Appellant City prays this court grant this first motion for extension and extend
the briefing deadline to January 14, 2016. The City further requests what other relief
it may be entitled to regarding this motion.
2