City of Leander Kent Cagle, Individually and in His Official Capacity as City Manager of the City of Leander and Thomas Yantis, Individually and in His Official Capacity as Assistant City Manager and Planning Director for the City of Leander v. Premas Global Leander I, LLC

Opinion

ACCEPTED

03-15-00377-CV

6368348

THIRD COURT OF APPEALS

AUSTIN, TEXAS

8/5/2015 1:59:07 PM

JEFFREY D. KYLE

CLERK

No. 03-15-00377-CV

FILED IN

IN THE COURT OF APPEALS FOR THE AUSTIN,OF 3rd COURT APPEALS

TEXAS

THIRD JUDICIAL DISTRICT OF TEXAS8/5/2015 1:59:07 PM AT AUSTIN, TEXAS JEFFREY D. KYLE Clerk

CITY OF LEANDER, et al., Appellants – Defendants,

V.

PREMAS GLOBAL LEANDER I, LLC, Appellee – Plaintiff.

Appeal from the 277th Judicial District Court of Williamson County, Texas Cause No. 15-0088-C277

APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF

Appellee Premas Global Leander I, LLC (Premas) files this unopposed motion

for extension of time to file its response brief, and in support therefore would

respectfully show as follows:

1. The current deadline for Premas to file its response brief is August 10,

2015.

2. Premas seeks a 21-day extension to file its response brief, making its

brief due on or before August 31, 2015.

3. Counsel for Premas has been heavily involved in numerous highly

complex matters in both state and federal court. This request is not for delay only,

but so that Premas’s positions and arguments may be fully developed and presented

to this Court in a concise and persuasive fashion.

4. This is the first request to extend the deadline for Premas’s response

brief.

5. Counsel for Premas has conferred with Counsel for Appellants, who

indicated he is unopposed to Premas’s request for an extension of time to file its

response brief.

WHEREFORE, PREMISES CONSIDERED, Premas respectfully requests an

order granting its Unopposed Motion for Extension of Time to File Response Brief

so that Premas’s response brief is due on or before August 31, 2015, and for such

other and further relief to which it may be entitled.

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Dated: August 5, 2015 Respectfully submitted,

HOWRY BREEN & HERMAN, LLP

_______________________________

Sean E. Breen State Bar No. 00783715 sbreen@howrybreen.com Randy R. Howry State Bar No. 10121690 rhowry@howrybreen.com James Hatchitt State Bar No. 24072478 jhatchitt@howrybreen.com 1900 Pearl Street Austin, Texas 78705-5408 Tel. (512) 474-7300 Fax (512) 474-8557

Attorneys for Plaintiff – Appellee Premas Global Leander I, LLC

CERTIFICATE OF CONFERENCE

I hereby certify that on August 5, 2015, I conferred with Counsel for Appellants by e-mail regarding the relief sought by this motion, and he indicated the motion is unopposed.

Sean E. Breen

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CERTIFICATE OF SERVICE

I certify that a true and correct copy of this document was delivered on August 5, 2015, in compliance with Rules 9.5(b) of the Texas Rules of Appellate Procedure, to the parties listed and in the manner indicated below.

Bradford E. Bullock  Electronic service bradford@cityattorneytexas.com □ In person KNIGHT & PARTNERS □ Registered mail, return receipt requested Executive Office Terrace □ Commercial delivery service 223 West Anderson Lane, Suite A- □ Facsimile 105  Electronic mail Austin, Texas 78752 Tel. (512) 323-5778 Fax (512) 323-5773

Attorney for Defendants – Appellants City of Leander, Kent Cagle, and Thomas Yantis

Sean E. Breen