the City of Luling v. Guadalupe Blanco River Authority

ACCEPTED
03-16-00552-CV
13673413
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/8/2016 9:31:13 AM
JEFFREY D. KYLE
CLERK
NO. 03-16-00552-CV
__________________________________________________________________
FILED IN
IN THE THIRD DISTRICT COURT OF APPEALS3rd COURT OF APPEALS
AUSTIN, TEXAS
AUSTIN, TEXAS 11/8/2016 9:31:13 AM
__________________________________________________________________
JEFFREY D. KYLE
Clerk
THE CITY OF LULING,

Appellant

v.

GUADALUPE-BLANCO RIVER AUTHORITY,

Appellee
__________________________________________________________________

Appealed from the 421st Judicial District Court
Caldwell County, Texas
The Honorable Todd Blomerth, Presiding
Trial Court Cause No. 15-O-544
__________________________________________________________________

UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT’S BRIEF
__________________________________________________________________

TO THE HONORABLE THIRD DISTRICT COURT OF APPEALS:

Appellant the City of Luling files this Unopposed Second Motion for Extension of

Time to File Appellant’s Brief.

As reported in the First Motion for Extension of Time, the parties in this matter

have engaged in settlement discussions. Those discussions have been productive and are

ongoing. Appellant believes that time for additional discussions will prove useful and

MOTION FOR EXTENSION OF TIME
may resolve the dispute at issue here. Appellant, therefore, seeks an extension of time to

continue and hopefully finalize such settlement discussions. A thirty-day extension of

time should provide enough time to determine whether a settlement may be possible.

This is Appellants’ second request for an extension of time for this filing.

Appellees are not opposed to the request.

PRAYER

For these reasons, Appellant, the City of Luling, prays that this Court grant a

thirty-day extension of time to file its Appellants’ Brief to and including December 14,

2016. Appellant also asks for any other relief to which it may be entitled.

Date: November 8, 2016

Respectfully submitted,

THE AL LAW GROUP, PLLC

/s/ David Tuckfield_____________
David Tuckfield
State Bar Number: 00795996
12400 West Hwy 71, Suite 350-150
Austin, TX 78738
Telephone: (512) 576-2481
Facsimile: (512) 366-9949

Eric B. Storm
State Bar No. 24033244
11610 Bee Caves Rd., Suite 220
Austin, TX 78738
Telephone: (512) 593-1881
Facsimile: (512) 276-6677

ATTORNEYS FOR APPELLANT THE
CITY OF LULING

MOTION FOR EXTENSION OF TIME
 CERTIFICATE OF CONFERENCE

I certify that I have conferred with Joseph R. Knight, counsel for Appellee,
regarding this motion and Appellee is not opposed to the relief sought in this motion.

/s/ David Tuckfield
David Tuckfield

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has been
served on this 8th day of November 2016 by e-file and/or electronic mail in accordance
with the Texas Rules of Civil Procedure to the following:

Joseph R. Knight
State Bar. No. 11601275
jknight@ebbklaw.com
111 Congress Ave., Suite 2800
Austin, Texas 78701
512.770.4010
512.684.7681 (facsimile)

Attorneys for Defendant Guadalupe Blanco River Authority

/s/ David Tuckfield
David Tuckfield

MOTION FOR EXTENSION OF TIME