Reagan National Advertising of Austin, Inc. D/B/A Reagan National Advertising v. City of Austin, Texas And Marc A. Ott, Being Sued in His Official Capacity

ACCEPTED
03-15-00370-CV
6784359
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/3/2015 1:40:43 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00370-CV
________________________________________________________________________
FILED IN
IN THE COURT OF APPEALS 3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE THIRD DISTRICT OF TEXAS
TRAVIS COUNTY, AUSTIN, TEXAS 9/3/2015 1:40:43 PM
JEFFREY D. KYLE
________________________________________________________________________
Clerk

REAGAN NATIONAL ADVERTISING OF AUSTIN, INC., APPELLANT

VS.

THE CITY OF AUSTIN AND MARC A. OTT, IN HIS OFFICIAL CAPACITY,
APPELLEES
________________________________________________________________________

ON APPEAL FROM
th
THE 200 JUDICIAL DISTRICT COURT
TRAVIS COUNTY, TEXAS
CAUSE NO. D-1-GN-12-001211
________________________________________________________________________

APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME
________________________________________________________________________

Appellant Reagan National Advertising of Austin files this unopposed motion

seeking a 14-day extension of the deadline for its Appellant’s Brief.

1. The deadline for Appellant’s Brief is Friday, September 11, 2015.

2. Appellant requests a 14-day extension until Friday, September 25, 2015.

This is Appellant’s second request for an extension. The first request was similarly for 14

days, as the original deadline on the brief was August 28, 2015.

3. The additional time is sought due to recent and unexpected demands on

counsel’s time in another matter, the deadline for which could not be extended by

agreement.

1
4. Appellees do not oppose the relief requested in this motion.

5. This extension is not sought for delay, but so that justice may be done.

For these reasons, Appellant prays that the Court grant an extension of its deadline

to file the Appellant’s Brief until September 25, 2015.

Respectfully submitted,

/s/ B. Russell Horton
B. Russell Horton
State Bar No. 10014450
rhorton@gbkh.com
George Brothers Kincaid & Horton, L.L.P.
114 West 7th Street, Suite 1100
Austin, Texas 78701
(512) 495-1400
(512) 499-0094 FACSIMILE
ATTORNEY FOR APPELLANT

CERTIFICATE OF CONFERENCE

Patricia Link indicated on September 3, 2015, that Appellees do not oppose the
relief requested in this motion.
/s/ B. Russell Horton
B. Russell Horton

CERTIFICATE OF SERVICE

The undersigned certifies that a copy of this motion was served on September 3,
2015, on the following through the court’s e-filing system:

Patricia L. Link
Gray Laird
City of Austin-Law Department
PO Box 1546
Austin, TX 78767-1546
512-974-1311 (facsimile)
patricia.link@austintexas.gov

/s/ B. Russell Horton
B. Russell Horton