ACCEPTED
14-14-00900-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/17/2015 4:54:42 PM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00900-CVV
IN THE FOURTEENTH COURT OF APPEALS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS HOUSTON, TEXAS
2/17/2015 4:54:42 PM
CHRISTOPHER A. PRINE
Steve Griffith in his Official Capacity, Douglas Brinkley in his OfficialClerk
Capacity,
Scott Schultz in his Official Capacity, and Mark Grothaus in his Official Capacity,
Appellants,
v.
Collision Clinic, L.L.P. and Hanna “John” Elias,
Appellees.
APPELLEES’ MOTION FOR EXTENSION OF TIME
TO FILE APPELLEES’ RESPONSE BRIEF
COME NOW, Collision Clinic, L.L.C. and Hanna “John” Elias, Appellees
herein, and move the Court for an extension of time to file Appellees’ Response
Brief in this cause, and in support thereof would show the Court as follows:
I.
This is an interlocutory appeal on an order denying a plea to the jurisdiction
pursuant to §51.014(a)(5) and (8), Tex. Civ. Prac. & Rem. Code. Appellants filed
their brief on or about January 21, 2015. Subsequently, a supplemental clerks
record was filed January 29, 2015. Appellees’ brief in response was due February
10, 2015.
II.
This is Appellees’ first request for an extension of time to file Appellees’
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Brief.
III.
Appellees hereby request a three week extension of time to file Appellees’
Response Brief until the 3rd day of March 2015, and as reasons therefore would show
the Court as follows:
The undersigned counsel has been in numerous depositions and hearings and
has had numerous briefs due in other matters in the last thirty days and therefore has
not been able to devote sufficient amount of time to the review of this entire record
and the preparation of the brief. In addition, the City of Sugar Land recently
adopted a resolution related to the underlying issue in the present lawsuit and
counsel for Appellees have needed time to analyze the impact of the resolution on
the present litigation.
IV.
Appellees have advised counsel for Appellants of their intent to file this
Motion for Extension of Time and requested they advise whether they are opposed
or unopposed. At the time of this filing, counsel for Appellees have not received a
response to their request.
WHEREFORE, PREMISES CONSIDERED, the undersigned counsel
respectfully prays that this Honorable Court extend the time for filing the Appellees=
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Response Brief in this cause until the 3rd day of March, 2015.
Respectfully submitted,
THE IRWIN LAW FIRM, P.C.
By: /s/ Leland M. Irwin
Leland M. Irwin
State Bar No. 00790945
leland@irwin-lawfirm.com
210 Morton Street
Richmond, Texas 77469
(832) 847-4111
Facsimile (832) 847-4177
-AND-
YOUNG AND HUSAIN, P.L.L.C.
By: /s/ Omar Khawaja
Omar Khawaja
State Bar No. 24072181
okhawaja@yhlawfirm.com
2700 Post Oak Blvd., Suite 1220
Houston, Texas 77056
713-621-8900
Facsimile 713-621-8909
ATTORNEYS FOR REAL PARTIES IN INTEREST
COLLISION CLINIC, L.L.C. AND HANNA
“JOHN” ELIAS
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VERIFICATION
STATE OF TEXAS §
§
COUNTY OF FORT BEND §
BEFORE ME, the undersigned Notary Public, on this day personally
appeared, Leland M. Irwin, who being by me duly sworn on his oath deposed and
said that he is the attorney for Collision Clinic, L.L.C. and Hanna "John" Elias,
Appellees in the above-entitled and numbered cause; that he has read the above and
foregoing Motion For Extension of Time to File Appellees' Response Brief; and that
every statement contained therein is within h. owledge and is true and correct.
SHERRIE MONTGOMERY
MY COMMISSION EXPIRES
March 9, 2015
Notary Public in and for the State of Texas
CERTIFICATE OF CONFERENCE
This is to certify that on February 17, 2015, I have attempted to confer with
Patricia L. Hayden, counsel for Appellants, via email regarding this Motion for
Extension of Time to File Appellees' Response Brief, and that she has not responded
to my request.
Isl Leland M Irwin
Leland M. Irwin
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CERTIFICATE OF SERVICE
I hereby certify that on February 17, 2015, a true and correct copy of this
document was served on the following counsel and respondent:
E-serve and Email: PHayden@OlsonLLP.com
Patricia L. Hayden
Olson & Olson, L.L.P.
209 e. Mulberry, Suite 100
Angleton, Texas 77515
Attorney for Defendants Steve Griffith,
Douglas Brinkley, Scott Schultz, and
Mark Grothaus
E-Serve and Email: don@dontschwartzlaw.com
Don T. Schwartz
Schwartz & Kalinowski, L.L.P.
1821 Mons Avenue
Rosenberg, TX 77471
Attorney for Defendant
A & M Wrecker Service
Facsimile 281/238-8514
And Email: mcdougal-law-larry@comcast.net
Larry P. McDougal
809 Houston St.
Richmond, TX 77469
Attorney for Defendant
J&H Towing and Recovery
Facsimile 713/802-1339
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Dan Reiver
1445 North Loop West, Suite 900
Houston, TX 77008
Attorney for Defendant
Long’ Towing, LLC
Facsimile 281/250-4253
Francisco R. Yeverino
112 W. 4th Street
Houston, TX 77007
Attorney for Defendant
Big Rod’s Towing, Inc.
Facsimile 713/789-7703
Daniel F. Castaneda
Buckley, White, Castaneda & Howell, L.L.P.
2401 Fountainview, Suite 1000
Houston, Texas 77057
Attorney for Defendant
Russell Rossett and Hadjes, Inc.
/s/ Leland M. Irwin
Leland M. Irwin
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