ACCEPTED
07-17-00096-CV
SEVENTH COURT OF APPEALS
AMARILLO, TEXAS
8/14/2017 3:46 PM
Vivian Long, Clerk
NO. 07-17-00096-CV
FILED IN
7th COURT OF APPEALS
IN THE AMARILLO, TEXAS
SEVENTH COURT OF APPEALS 8/14/2017 3:46:59 PM
AMARILLO, TEXAS VIVIAN LONG
CLERK
LAZARO WALCK
Appellant,
V
CITY OF LUBBOCK
Appellee.
On Appeal from the 72nd District Court of Lubbock County, Texas, Lazaro Walck
v. City of Lubbock, Cause No. 2014-509,907
UNOPPOSED MOTION TO EXTEND TIME
FOR FILING APPELLEE’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
COMES NOW, CITY OF LUBBOCK, Appellee, and moves this Honorable
Court to grant a thirty (30) day extension of time to file Appellee’s Brief, and would
respectfully show as follows:
1. The City of Lubbock’s Brief is due to be filed with this Court on August
28, 2017.
2. City of Lubbock seeks a 30 day extension of time to file it’s Brief,
which would make the Brief due on September 28, 2017.
3. This requested extension is requested as counsel for the City of
Lubbock is preparing briefs in other cases that are due on August 25, 2017 and
September 8, 2017, in which there are unique issues of law that require extensive
briefing and research. As such, counsel does not believe that he will have sufficient
time before August 28, 2017, to properly prepare the brief on the issues that will be
presented in this appeal.
4. Counsel for the City has conferred with counsel for Lazaro Walck and
he does not oppose this extension.
5. This is the first extension of time that the City of Lubbock has sought
for the filing of its Brief, and this request for extension is not sought for delay, but
in order that justice might be done.
For these reasons, CITY OF LUBBOCK requests that this Court grant this
motion, and render an order extending the time for filing its Brief to September 28,
2017.
Respectfully submitted,
JEFF HARTSELL
Assistant City Attorney
State Bar No. 09170275
P O Box 2000
Lubbock, Texas 79457
806-775-2222
Fax 806-775-3307
Email: jhartsell@mylubbock.us
/s/ Jeff Hartsell
JEFF HARTSELL
CERTIFICATE OF CONFERENCE
THIS IS TO CERTIFY that the undersigned counsel for Appellee CITY OF
LUBBOCK, has conferred with counsel for Appellant, Phil Johnson, regarding this
motion and he does not oppose this motion.
/s/ Jeff Hartsell
JEFF HARTSELL
CERTIFICATE OF SERVICE
I hereby certify that on the 14th day of August, 2017, I electronically filed the
foregoing document with the Seventh Court of Appeals using an e-filing service
provider. The electronic filing system sent a “Notification of Service” to the
following by electronic means.
Phil A. Johnson
Jenkins, Wagnon & Young, P.C.
P O Box 420
Lubbock, Texas 79408
pjohnson@jwylaw.com
/S/ Jeff Hartsell
JEFF HARTSELL