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No. 14-15-00414-CV 

In re Southern American Insurance, § In the Fourteenth

Agency, Inc., Al McClure, Dalina § 

St. Lawrence, and Gwen Crosby, § Court of Appeals

 § 

 Relators § at Houston, Texas

SECOND AGREED MOTION FOR EXTENSION OF

TIME TO FILE MANDAMUS RESPONSE

Relators Southern American Insurance Agency, Inc., Al McClure, Dalina St. 

Lawrence, and Gwen Crosby (“Southern American”); Relators Hull and 

Company, Inc., Karen Noyes, and Cindy Winchcombe (“Hull and Company”); and 

Real Parties in Interest Heather Haygood, Individually and as Next Friend of J.A., 

a Minor, and Lynn Klement, on behalf of Heather Haygood, and J.A. (“Haygood”) 

file this Agreed Motion for Extension of Time to File Mandamus Response and 

would respectfully show:

Southern American filed its Petition for Writ of Mandamus on May 7, 2015, 

and Hull and Company filed its Joinder in the petition the same day. On May 13, 

2015, this Court requested that Haygood file a response to the mandamus petitions 

by May 28, 2015. This Court granted an extension until July 15, 2015 on May 27, 

2015. The parties mediated the case on June 15, 2015 and Haygood and Southern 

American reached a settlement. Upon the parties’ motions, the trial court lifted the 

stay in order to appoint a guardian ad litem on July 8, 2015. The parties intend to 

set a hearing under Texas Rule of Civil Procedure 44(2) as soon as possible. 

ACCEPTED

14-15-00414-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

7/14/2015 3:34:31 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/14/2015 3:34:31 PM CHRISTOPHER A. PRINE Clerk
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Postponing the mandamus response deadline will allow Haygood to avoid 

the potentially needless expense of drafting a response if the case proceeds to settle

with the trial court’s approval; it will also prevent the Court from wasting judicial 

resources in considering mandamus petitions that could be rendered moot by a 

settlement. Accordingly, the parties are jointly requesting that the Court extend the 

deadline for Haygood to file her mandamus response for an additional thirty days, 

or August 14, 2015. See Tex. R. App. P. 10.5(b). This is the second request for an 

extension of time to file the mandamus response.

For these reasons, the parties respectfully request that the Court grant this 

motion and extend the deadline for Haygood to file her response to the mandamus 

petitions until August 14, 2015.

Respectfully submitted, 

HENDLER LYONS FLORES, PLLC

By: /s/ Rebecca R. Webber

Rebecca R. Webber

State Bar No. 24060805

Scott M. Hendler

State Bar No. 09445500

1301 W. 25th Street, Suite 400

Austin, Texas 78705

Telephone: (512) 439-3200

Email: rwebber@hendlerlaw.com

Email: shendler@hendlerlaw.com
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Troy Chandler

State Bar No. 24006982

CHANDLER MCNULTY, LLP

1001 West Loop South, Suite 602

Houston, Texas 77027

Email: Troy@chandlermcnulty.com

Counsel for Real Parties in Interest 

Heather Haygood, Individually and as Next

Friend of J.A., a Minor, and Lynn 

Klement, on behalf of Heather Haygood 

and J.A.

CERTIFICATE OF CONFERENCE

I hereby certify that Counsel for Plaintiff has conferred with Amy Greene, 

counsel for Defendant Hull & Co. et al, and Danielle Maya, counsel for Southern 

American, et al, and certify that defendants are unopposed to this motion. 
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CERTIFICATE OF SERVICE

I certify that on July 14, 2015, a true and correct copy of this Second Agreed 

Motion for Extension of Time was served on the persons listed below by electronic 

service, email, or certified mail:

The Honorable Kyle Carter

125th Judicial District Court

Harris County Civil Courthouse

201 Caroline, 10th Floor

Houston, Texas 77002

Respondent

Thompson, Coe, Cousins & Irons

J. Richard Harmon 

rharmon@thompsoncoe.com

700 N. Pearl Street, Suite 2500

Dallas, Texas 75201

Danielle F. Maya 

dmaya@thompsoncoe.com

One Riverway, Suite 1400 

Houston, Texas 77056 

Courtney K. Walsh 

cwalsh@thompsoncoe.com

One Riverway, Suite 1400 

Houston, Texas 77056 

Attorneys for Defendants Southern American Insurance Agency, Inc., Al 

McClure, Gwen Crosby, and Dalina St. Lawrence

Phelps Dunbar, LLP

Mary “Amy” Cazes Greene

Amy.greene@phelps.com

One Allen Center

500 Dallas Street, Suite 1300

Houston, Texas 77002

Attorney for Defendants Hull & Company, Inc., Karen Noyes, and Cindy 

Winchcombe

/s/ Rebecca R. Webber

Rebecca R. Webber