the City of Luling v. Guadalupe Blanco River Authority ( 2016 )

ACCEPTED 03-16-00552-CV 13673413 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/8/2016 9:31:13 AM JEFFREY D. KYLE CLERK NO. 03-16-00552-CV __________________________________________________________________ FILED IN IN THE THIRD DISTRICT COURT OF APPEALS3rd COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 11/8/2016 9:31:13 AM __________________________________________________________________ JEFFREY D. KYLE Clerk THE CITY OF LULING, Appellant v. GUADALUPE-BLANCO RIVER AUTHORITY, Appellee __________________________________________________________________ Appealed from the 421st Judicial District Court Caldwell County, Texas The Honorable Todd Blomerth, Presiding Trial Court Cause No. 15-O-544 __________________________________________________________________ UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF __________________________________________________________________ TO THE HONORABLE THIRD DISTRICT COURT OF APPEALS: Appellant the City of Luling files this Unopposed Second Motion for Extension of Time to File Appellant’s Brief. As reported in the First Motion for Extension of Time, the parties in this matter have engaged in settlement discussions. Those discussions have been productive and are ongoing. Appellant believes that time for additional discussions will prove useful and MOTION FOR EXTENSION OF TIME may resolve the dispute at issue here. Appellant, therefore, seeks an extension of time to continue and hopefully finalize such settlement discussions. A thirty-day extension of time should provide enough time to determine whether a settlement may be possible. This is Appellants’ second request for an extension of time for this filing. Appellees are not opposed to the request. PRAYER For these reasons, Appellant, the City of Luling, prays that this Court grant a thirty-day extension of time to file its Appellants’ Brief to and including December 14, 2016. Appellant also asks for any other relief to which it may be entitled. Date: November 8, 2016 Respectfully submitted, THE AL LAW GROUP, PLLC /s/ David Tuckfield_____________ David Tuckfield State Bar Number: 00795996 12400 West Hwy 71, Suite 350-150 Austin, TX 78738 Telephone: (512) 576-2481 Facsimile: (512) 366-9949 Eric B. Storm State Bar No. 24033244 11610 Bee Caves Rd., Suite 220 Austin, TX 78738 Telephone: (512) 593-1881 Facsimile: (512) 276-6677 ATTORNEYS FOR APPELLANT THE CITY OF LULING MOTION FOR EXTENSION OF TIME CERTIFICATE OF CONFERENCE I certify that I have conferred with Joseph R. Knight, counsel for Appellee, regarding this motion and Appellee is not opposed to the relief sought in this motion. /s/ David Tuckfield David Tuckfield CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been served on this 8th day of November 2016 by e-file and/or electronic mail in accordance with the Texas Rules of Civil Procedure to the following: Joseph R. Knight State Bar. No. 11601275 jknight@ebbklaw.com 111 Congress Ave., Suite 2800 Austin, Texas 78701 512.770.4010 512.684.7681 (facsimile) Attorneys for Defendant Guadalupe Blanco River Authority /s/ David Tuckfield David Tuckfield MOTION FOR EXTENSION OF TIME