April Brown, David Rafferty, Steve Gann, Kathy Hilton, Irene Garcia and Steve Stuckey v. William Hensley, Tom Jenkins, Troy Jones, David Marks, Barnard Pearl, Thomas Walsh, Stan Williams, Jack Ereira and Andrew Rosenberg

Opinion

ACCEPTED 14-14-00981-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/9/2015 12:00:34 PM CHRISTOPHER PRINE CLERK

IN THE COURT OF APPEALS FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS AT HOUSTON FILED IN 14th COURT OF APPEALS ______________________________________________________ HOUSTON, TEXAS 6/9/2015 12:00:34 PM No. 14-14-00981-CV CHRISTOPHER A. PRINE Clerk _______________________________________________________

DAVID RAFFERTY, STEVE GANN, KATHY HILTON, IRENE GARCIA, STEVE STUCKEY and APRIL BROWN Appellants,

v.

THE LANDING COUNSEL OF CO-OWNERS, ET AL. Appellees. __________________________________________________________________

On Appeal from the 127th Judicial District Court of Harris County, Texas Trial Court Cause No. 2010-56653-B __________________________________________________________________

THIRD AGREED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF

TO THE HONORABLE JUDGE OF THIS COURT:

COME NOW, April Brown, David Rafferty, Steve Gann, Kathy Hilton,

Irene Garcia and Steve Stuckey (hereinafter “Appellants”) in the above-referenced

matter and file this Second Agreed Motion for Extension of Time to File

Appellants’ Brief and, as such, will show as follows:

1. Appellants’ Brief was originally due to be filed with this Court on

April 13, 2015. This Court granted an extension, making the Brief due on May 13,

1 2015 and another extension making it due on June 12, 2015. Appellants seek an

additional 30 day extension, making Appellants’ Brief due on July 13, 2015.

2. The undersigned is lead counsel in a matter that is going before the

Planning Commission in San Antonio on June 10, 2015. Additionally, Counsel has

a trial scheduled for the docket beginning June 15, 2015 in Harris County District

Court. The case is third on the docket, so it is likely to get reached. As such,

Counsel has spent this week preparing for trial. As a result of this, Counsel has

been unable to give significant attention to this matter. Accordingly, due to these

matters and other pending trial court matters that require immediate attention of

counsel, Appellants request a thirty day extension of its June 12 Brief deadline.

3. Appellants do not seek this extension merely for the sake of seeking a

delay in the proceedings. To the contrary, Appellants are simply asking for some

additional time to so that counsel has sufficient time to research, draft and file their

Brief. The undersigned has conferred with counsel for Appellees in this matter and

she has indicated that they are unopposed to this Motion.

PRAYER

Appellants respectfully request that the Court grant their Unopposed Motion

for Extension of Time to File Appellants’ Brief and extend the June 13 deadline by

thirty (30) days.

2 Respectfully Submitted,

Andy Taylor & Associates, P.C.

BY: /s/Andy Taylor Andy Taylor State Bar No. 19727600 2668 Highway 36 S, #288 Brenham, Texas 77833 713-222-1817 (telephone) 713-222-1855 (facsimile)

CERTIFICATE OF SERVICE

I certify that on June 9, 2015, I conferred with Shelley White, counsel for Appellees, in this matter and he indicated that he is unopposed to the relief sought in this motion.

/s/ Amanda Peterson Amanda Peterson

I hereby certify that a true and correct copy of the foregoing document was served via electronic service to the following counsel of record on June 9, 2015.

Shelley White, Henry Platts, Jr., Howard Close, 713-572-4320 Tod Phillips, Patrick McAndrew

/s/ Andy Taylor Andy Taylor