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NO. 14-15-00280-CV

 

IN THE COURT OF APPEALS

FOURTEENTH JUDICIAL DISTRICT

HOUSTON, TEXAS

 

CONRAD CONSTRUCTION CO., LTD. 

 APPELLANT

VS. 

FREEDMEN’S TOWN PRESERVATION COALITION, 

CATHERINE ROBERTS AND GLADYS HOUSE

 APPELLEES

 

FROM THE 80TH JUDICIAL DISTRICT COURT

OF HARRIS COUNTY, TEXAS

(TRIAL COURT CAUSE NO. 2015-02771) 

 

APPELLEES’ UNOPPOSED MOTION FOR LEAVE

TO FILE RESPONSE BRIEF OUT-OF-TIME

 

TO THE HONORABLE COURT OF APPEALS: 

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

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 6/17/2015 2:24:01 PM CHRISTOPHER A. PRINE Clerk
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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 80th 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 during 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 simultaneously with this Motion. Appellees 

accordingly request leave of the Court to file their Response Brief five days 
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subsequent to its due date of June 12, 2015, as extended previously by this 

Court.

4. Counsel for Appellant, Robert A. Plessala, has advised the 

undersigned counsel for Appellees that he does not oppose the relief 

requested by this Motion.

WHEREFORE, PREMISES CONSIDERED, Appellees respectfully request 

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

after the extended due date previously ordered by the Court.

SIGNED AND FILED this 17th day of June, 2015.
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Respectfully submitted,

THE HALL LAW FIRM

/s/William L. Van Fleet

Benjamin L. Hall III

Texas Bar No. 08743745

William L. Van 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

ATTORNEYS FOR APPELLEES

FREEDMEN’S TOWN PRESERVATION

COALITION, CATHERINE ROBERTS,

AND GLADYS HOUSE

CERTIFICATE OF CONFERENCE

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

Robert A. Plessala, counsel for Appellant 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 II
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CERTIFICATE OF COMPLIANCE (RULE 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 17th day of June, 2015, a true and correct 

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