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T O THE H ONORABLE C OURT OF A PPEALS :

Appellees Freedmen’s Town Preservation Coalition, Catherine

Roberts and Gladys House file this Second Unopposed Motion for ACCEPTED

14-15-00280-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

6/17/2015 2:24:01 PM

CHRISTOPHER PRINE

CLERK2

Extension of Time to file Response Brief and would respectfully show the

Court the following:

1. In this interlocutory appeal from a temporary injunction entered

by the 80 th Judicial District Court of Harris County, Texas, Appellant Conrad

Construction Co., Ltd. filed its initial brief on April 24, 2015. Pursuant to

Tex.R.App.Pro. 38.6(b), Appellees’ responsive brief was initially due May

13, 2015. This Court, however, granted Appellees’ Unopposed Motion for

Extension of Time to File Response Brief extending the date for Appellees

to file their brief to and through June 12, 2015.

2. On June 9, 2015, Appellees filed their Second Unopposed

Motion for Extension of Time to File Response Brief, requesting that the

Court further extend the date for filing Appellees’ Response Brief to and

through June 26, 2015, due to intermittent internet outages Appellees’

counsel suffered dur ing and after the storms which inundated the Houston

and Harris County area during the Memorial Day holidays. That motion

has yet to be ruled upon by the Court.

3. Appellees’ counsel has now completed the Response Brief and

has efiled it with the Court s imultaneously with this Motion. Appellees

accordingly request leave of the Court to file their Response Brief five days3

subsequent to its due date of June 12, 2015 , as extended previously by this

Court

.

4. Counsel for Appellant, Robert A. Plessala, has ad vised the

undersigned counsel for Appellees that he does not oppose the relief

requested by this Motion.

W HEREFORE

, PREMISES CONSIDERED

, Appellees respectfully request

that the Court grant Appellees leave to file their Response Brief five days

after the e xtended due date previously ordered by the Court.

S IGNED AND F ILED this 17 th day of June , 2015.4 Respectfully submitted,

T HE H ALL L AW F

IRM

/s/ William L. Van Fleet

Benjamin L. Hall III

Texas Bar No. 08743745

William L. V an Fleet II

Texas Bar No. 20494750

Kimmie R. Bennett

State Bar No. 24011946

530 Lovett Blvd.

Houston, TX 77006

(713) 942

- 9600 (Telephone)

(713) 942

- 9566 (Facsimile)

bvfleet@comcast.net

A TTORNEYS FOR A PPELLEES

F REEDMEN ’ S T OWN P RESERVATION

C OALITION

, C ATHERINE R OBERTS

,

AND G LADYS H OUSE

C ERTIFICATE OF C ONFERENCE

The undersigned certifies that on June 17, 2015, he conferred with

Robert A. Plessala, counsel for Appel lant Conrad Construction Co., Ltd.,

who advised that he does not oppose the relief requested in the above and

foregoing Motion.

/s/ William L. Van Fleet

William L. Van Fleet II5 C ERTIFICATE OF C OMPLIANCE (R ULE 9.4)

The undersigned certifies that the above and foregoing Motion satisfies

the requirements of Tex.R.App.P. 9.4 because the Motion contains 556

words.

/s/ William L. Van Fleet II

William L. Van Fleet II

CERTIFICATE OF SERVICE

I hereby certify that on the 17 th day of June, 2015 , a true and corr ect

copy of the foregoing Motion was forwarded to counsel for Conrad

Construction Co., Ltd., Robert A. Plessala, Andrews Myers, P.C., 3900

Essex Lane, Suite 800, Houston, Texas 77027, via email at

rplessala@andrewsmyers.com.

/s/ William L. Van Fleet

William L. Van Fleet II