Annise D. Parker, Mayor, Anna Russell, City Secretary, and City of Houston v. David B. Wilson

Opinion

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 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

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)

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