ACCEPTED
01-15-00117-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/6/2015 3:06:33 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00117-CV
FILED IN
1st COURT OF APPEALS
IN THE FIRST COURT OF APPEALS, HOUSTONHOUSTON, TEXAS
10/6/2015 3:06:33 PM
CHRISTOPHER A. PRINE
League City, Clerk
Appellant,
v.
Texas Windstorm Insurance Association,
Appellee.
On Appeal from the
10th District Court at Galveston, Texas
No. 12-CV-0053
UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S RESPONSIVE BRIEF
Dale Wainwright
dale.wainwright@bgllp.com
State Bar No. 00000049
Lindsay E. Hagans
State Bar No. 24087651
lindsay.hagans@bgllp.com
BRACEWELL & GIULIANI LLP
111 Congress Avenue, Suite 2300
Austin, Texas 78701
Telephone: (512) 472-7800
Facsimile: (800) 404-3970
ATTORNEYS FOR APPELLEE
TEXAS WINDSTORM INSURANCE ASSOCIATION
Pursuant to Texas Rule of Appellate Procedure 10.5(b), Appellee Texas
Windstorm Insurance Association (“TWIA”) files its Second Motion for Extension
of Time to file its brief.
TWIA’s brief is currently due on October 8, 2015. This is TWIA’s second
request for an extension of thirty days in which to file its brief, which would make
the Brief of Appellee due on November 9, 2015. League City does not oppose this
requested extension.
TWIA needs a thirty-day extension of time to file its brief because since
filing the last motion for extension, counsel was set for oral argument on October
14, 2015, in the appeal Coyote Lake Ranch LLC v. the City of Lubbock, No. 14-
0572, in the Texas Supreme Court, and have briefs due in other appeals including
Westlake Ethylene Pipeline Corp. v. Railroad Commission of Texas, No. D-1-GN-
15-001009 in the 98th Judicial Distrct Court of Travis County, Texas
(administrative appeal that goes first to the District Court). Also, TWIA’s trial
counsel, whose institutional knowledge of this long and complicated case is
invaluable to the appeal, are in the midst of other Hurricane Ike litigation. A short,
thirty-day extension of time would allow for cogent, thoughtful preparation of the
brief.
PRAYER
For these reasons, Appellee Texas Windstorm Insurance Association prays
this Court grant a thirty-day extension of time to file its brief, to and including
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November 9, 2015. Appellee also prays for such further relief to which it may be
entitled.
Respectfully submitted,
BRACEWELL & GIULIANI LLP
By:/s/ Dale Wainwright
Dale Wainwright
State Bar No. 00000049
Lindsay E. Hagans
State Bar No. 24087651
111 Congress Avenue, Suite 2300
Austin, Texas 78701
Telephone: (512) 472-7800
Facsimile: (800) 404-3970
dale.wainwright@bgllp.com
lindsay.hagans@bgllp.com
ATTORNEYS FOR APPELLEE
TEXAS WINDSTORM INSURANCE
ASSOCIATION
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CERTIFICATE OF CONFERENCE
I certify that I have conferred with counsel for the Appellant League City
regarding the relief sought in this motion. Appellant League City is not opposed to
the relief sought in this motion.
/s/ Dale Wainwright
Dale Wainwright
CERTIFICATE OF SERVICE
I certify that a copy of the Second Motion for Extension of Time to file
Appellee’s Brief was served on counsel of record through the Court’s e-filing
system on October 6, 2015, to the following:
Gregory F. Cox
Michael R. Ramsey
THE MOSTYN LAW FIRM
6280 Delaware Street
Beaumont, Texas 77706
Facsimile: (409) 832-2703
Jennifer Bruch Hogan
HOGAN & HOGAN
2 Houston Center
909 Fannin, Suite 2700
Houston, Texas 77010
Facsimile: 713-222-8810
Attorneys For Appellant
League City
/s/ Dale Wainwright
Dale Wainwright
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