No. 03-15-00292-CV

In the Third Court of Appeals 

Austin, Texas 

THE CITY OF AUSTIN

Appellant 

V. 

JENNIFER FRAME, INDIVIDUALLY, AND AS PERSONAL 

REPRESENTATIVE OF THE ESTATE OF JOHN WILLIAM GRIFFITH,

GREG GRIFFITH, CHERYL BURRIS AND DIANA PULIDO

Appellee

APPEAL FROM CAUSE NO. D-1-GN-12-003557 

53RD JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS 

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLEES’ RESPONSE BRIEF 

Sean E. Breen Mike Davis 

State Bar No. 00783715 State Bar No. 05549500 

HOWRY BREEN & HERMAN, L.L.P. SLACK & DAVIS, L.L.P. 

1900 Pearl Street 2705 Bee Cave Road, Suite 220 

Austin, Texas 78705 Austin, Texas 78746 

Telephone (512) 474-7300 Telephone (512) 795-8686 

Facsimile (512) 474-8557(fax) Facsimile (512) 795-8787 

sbreen@howrybreen.com mdavis@slackdavis.com

ATTORNEYS FOR APPELLEES 

ACCEPTED

03-15-00292-CV

6006954

THIRD COURT OF APPEALS

AUSTIN, TEXAS

7/9/2015 4:52:35 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/9/2015 4:52:35 PM JEFFREY D. KYLE Clerk
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APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE 

RESPONSE BRIEF

COME NOW Appellees, Jennifer Frame, Individually, and as Personal 

Representative of the Estate of John William Griffith, Greg Griffith, Cheryl Burris 

and Diana Pulido and files this Unopposed Motion for Extension of Time to File 

Appellees’ Response Brief and in support thereof, would show as follows:

1. The current deadline for filing Appellees’ Response Brief is July 13, 

2015.

2. Appellees seek a thirty-day extension to file their brief, making the 

brief due on or before August 12, 2015.

3. The undersigned counsel has been heavily involved in numerous 

highly complex matters in Federal and State Court, which necessitate this request. 

This request is not for delay only.

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

brief.

5. Counsel has conferred with Counsel for Appellant and she has no 

objection and indicates the motion is unopposed.

WHEREFORE, Appellees respectfully ask the Court to grant the Motion to 

Extend Time to File Appellees’ Response Brief so that Appellees’ response is due 

on August 12, 2015 and to grant such other relief to which they may be entitled.
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Respectfully submitted,

 /s/ Sean E. Breen

Sean E. Breen

State Bar No. 00783715

HOWRY BREEN & HERMAN, L.L.P.

1900 Pearl Street

Austin, Texas 78705

(512) 474-7300

(512) 474-8557(fax)

sbreen@howrybreen.com

Mike Davis

State Bar No. 05549500

mdavis@slackdavis.com

SLACK & DAVIS, L.L.P.

2705 Bee Cave Road, Suite 220

Austin, Texas 78746

Telephone: (512) 795-8686

Facsimile: (512) 795-8787

Counsel for Appellee 

CERTIFICATE OF CONFERENCE

I hereby certify that on July 9, 2015 I conferred with Counsel for Appellant 

regarding this motion and she does not oppose this motion.

/s/ Sean E. Breen

Sean E. Breen
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CERTIFICATE OF SERVICE

This is to certify that I have served a copy of the foregoing on all parties, or their 

attorneys of record, in compliance with the Appellate Rules of Civil Procedure, 

this 9th day of July, 2015.

Chris Edwards

Assistant City Attorney

State Bar No. 00789276

chris.edwards@austintexas.gov

City of Austin - Law Department

P.O. Box 1546

Austin, Texas 78767-1546

Telephone (512) 974-2419

Facsimile (512) 974-1311

/s/ Sean E. Breen

Sean E. Breen