NO. 01-14-00866-CV 

______________________________________ 

IN THE FIRST COURT OF APPEALS 

HOUSTON, TEXAS 

______________________________________ 

CONNIE ROGGE, Individually and as heir of Richard Hollas Rogge; RICHARD 

ROGGE, Individually and as Heir of Richard Hollas Rogge; and RICHARD 

ROGGE as Administrator of the Estate of RICHARD HOLLAS ROGGE, 

Plaintiffs-Appellants,

vs. 

THE CITY OF RICHMOND, TEXAS; TODD GANEY; and DANELL GAYDOS, 

Defendants-Appellees.

______________________________________ 

On Appeal from the 268th Judicial District Court 

of Fort Bend County, Texas 

Trial Court Cause No. 11-DCV-194261 

______________________________________ 

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLEE’S BRIEF 

______________________________________ 

CHAMBERLAIN, HRDLICKA, WHITE, 

WILLIAMS & AUGHTRY 

WILLIAM S. HELFAND 

NORMAN RAY GILES 

1200 Smith Street, Suite 1400 

Houston, Texas 77002-4401 

Tel: (713) 654-9630; Fax: (713) 658-2553 

ATTORNEYS FOR APPELLEE, 

THE CITY OF RICHMOND, TEXAS 

ACCEPTED

01-14-00866-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

1/26/2015 1:12:03 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 1/26/2015 1:12:03 PM CHRISTOPHER A. PRINE Clerk
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TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: 

COMES NOW, The City of Richmond, Texas, Appellee herein, by and 

through its undersigned counsel, and files this Unopposed Motion for Extension of 

Time to File Appellee’s Brief in compliance with Rules 38.6(d) and 10.5 of the 

Texas Rules of Appellate Procedure. In support of this motion, Appellee would 

show as follows: 

1. Appellee’s brief is currently due on January 28, 2015. 

2. This is Appellee’s first request for an extension of time in which to 

file its brief. 

3. Appellee requests a twenty-one day extension of time to file its brief, 

up to and including February 18, 2015. 

4. Appellee is requesting this extension so that it might adequately brief 

the issues in dispute in this case, and it is not sought for the purpose of an improper 

delay. 

5. The good cause which requires Appellee’s counsel to seek an 

extension is as follows. The undersigned counsel has responsibility for preparation 

of Appellee’s brief on appeal, but has been unable to complete the brief by 

January 28, 2015, due to his involvement in the following matters which are within 

the personal knowledge of the undersigned. 
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a. January 12, 2015 - SOAH Docket No. 407-14-3991.F-5 

Administrative Hearing; Pamela A. Guerra v. Arcola Police 

Department 

b. January 15, 2015 – Status conference with Court; C.A. no. 

4:09-cv-03332; Steve Hobart, et al v. City of Stafford, et al; 

U.S. District Court, Southern District of Texas 

c. January 16, 2015 – Hearing – C.A. No. 4:14-cv-03135; Michael 

Williams, et al v. John W. Focke, et al; U.S. District Court, 

Southern District of Texas 

d. January 19, 2015 – Mediation in Los Angeles, CA on Case No. 

37-2014-00006422-CU-OE-CTL; Audrey Stanford, et al v. GC 

Services Ltd. Partnership; 

e. January 21, 2015 – hearing on Motion for Summary Judgment 

in Richmond, TX; Cause No. 12-DCV-200051 Fort Bend Co.; 

Leon Kaplan v. City of Sugar Lane; 240th District Court of Fort 

Bend County, Texas 

f. January 23, 2015 – Speaking engagement at an Employment 

Law Seminar. 

6. The undersigned has conferred with counsel for the Appellant, and the 

Appellant is unopposed to this motion. 

WHEREFORE, PREMISES CONSIDERED, Appellee respectfully requests 

this court grant an extension of twenty-one (21) days to allow Appellee to file its 

brief, up to and including February 18, 2015. Appellee further requests general 

relief. 
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 Respectfully submitted, 

 CHAMBERLAIN, HRDLICKA, WHITE, 

 WILLIAMS & AUGHTRY 

 By: /s/ William S. Helfand 

WILLIAM S. HELFAND 

Attorney-in-Charge 

 SBOT # 09388250 

 Norman Ray Giles 

 SBOT # 24014084 

ATTORNEYS FOR APPELLEE, 

THE CITY OF RICHMOND, TEXAS 

OF COUNSEL: 

CHAMBERLAIN, HRDLICKA, WHITE, 

 WILLIAMS & AUGHTRY 

1200 Smith Street, Suite 1400 

Houston, Texas 77002-4401 

(713) 654-9630 

(713) 658-2553 (Fax) 

 
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CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing instrument has 

been served via hand delivery, electronic submission, facsimile, U.S. Mail, and/or 

certified mail, return receipt requested, on this the 26th day of January, 2015, to the 

following: 

L. James Krell 

Ron S. Rainey 

Tritico Raney, PLLC 

1212 Durham Drive 

Houston, Texas 77007 

jkrell@triticorainey.com 

rrainey@triticorainey.com 

Neil C. McCabe 

The McCabe Law Firm 

Post Office Box 301101 

Houston, Texas 77230 

neilm@ncmlegal.com 

 /s/ William S. Helfand 

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