ACCEPTED
01-15-00687-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/20/2015 5:40:13 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00687-CV
_________________________________ FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS FOR HOUSTON, TEXAS
THE FIRST SUPREME JUDICIAL DISTRICT OF 11/20/2015
TEXAS 5:40:13 PM
_________________________________ CHRISTOPHER A. PRINE
Clerk
Annise D. Parker, Mayor, Anna Russell, City Secretary,
and City of Houston
vs.
David B. Wilson
_________________________________
Trial Court Number 2015-39706
270th District Court of Harris County, Texas
____________________________________
APPELLEE’S FIRST MOTION TO EXTEND TIME
TO FILE BRIEF
TO THE HONORABLE FIRST COURT OF APPEALS:
COMES NOW, Appellee, David Wilson, Defendant below in Trial Court
Number 2015-39706, 270th Judicial District Court of Harris County, Texas,
Honorable Brent Gambel, presiding, and respectfully submits this its First Motion to
Extend Time to File Brief.
1. The Appellant’s brief was due November 16, 2015. Appellant seeks a
extension to November 20, 2015. An extension is needed because Appellant’s
counsel was in trial the week of the 16th, and was unable to complete the brief. filing
The brief is concurrently filed with this motion. No Previous extensions have been
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sought for this matter.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court
grant the motion to extend time, and for such other and further relief as is just.
Respectfully submitted,
___/S/James D. Pierce________
James D. Pierce(15994500)
1 Sugar Creek Center Suite 1080
Sugar Land, TX 77478
(713) 650-0150
jim@jamespierce.com
ATTORNEY FOR APPELLEE
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CERTIFICATE OF CONFERENCE
Because he has been on vaction, counsel has not yet conferred with Counsel
for Appellee but will supplement after conferring.
___/S/James D. Pierce________
James D. Pierce(15994500)
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CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing brief has been
served on the below listed counsel of record this 20TH day of November, 2015
through the Court’s Electronic Filing System.
Respondents
Annise D. Parker, Mayor, Anna Russell, City Secretary, and City of Houston
Attorneys
Donna Edmundson City Attorney
Judith L. Ramsey Chief, General Litigation Section
Kathleen Hopkins
Alsina Senior Assistant City Attorney State Bar No. 09977050
Patricia L. Casey Senior Assistant City Attorney
State Bar No. 03959075 CITY OF HOUSTON LEGAL DEPARTMENT 900 Bagby,
Fourth Floor Houston, Texas 77002 832.393.6491 (Telephone) 832.393.6259
(Facsimile) kate.alsina@houstontx.gov pat.casey@houstontx.gov
___/S/James D. Pierce________
James D. Pierce
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