Manor Independent School District v. Deydra Steans ( 2015 )

ACCEPTED 03-15-00294-CV 5840814 THIRD COURT OF APPEALS AUSTIN, TEXAS 6/26/2015 12:32:22 PM JEFFREY D. KYLE CLERK NO. 03-15-00294-CV IN THE COURT OF APPEALS FILED IN FOR THE THIRD DISTRICT OF TEXAS3rd COURT OF APPEALS AUSTIN, TEXAS 6/26/2015 12:32:22 PM MANOR INDEPENDENT SCHOOL DISTRICTJEFFREY D. KYLE Clerk Appellant v. DEYDRA STEANS Appellee From the 200th Judicial District Court of Travis County, Texas APPELLEE’S MOTION TO EXTEND TIME TO FILE RESPONSE TO APPELLANT’S MOTION TO STAY Appellee Deydra Steans asks the Court to extend the time to file her response to Appellant’s Motion to Stay. A. Introduction 1. Appellant is Manor Independent School District. 2. Appellee is Deydra Steans. 3. The deadline to file this response is June 26, 2015. 4. The parties have agreed to this motion. B. Argument and Authorities 5. The Court has authority under TRAP 55.7 and 10.5 to extend the time to file her response. 6. Appellee requests an additional 30 days for file her response to Appellant’s Motion to Stay. 7. Appellant needs additional time because the parties are engaged in settlement negotiations and the parties believe the matter has settled. A preliminary mediator proposal has been approved by both sides and the parties are still in the process of attempting to finalize the settlement agreement. C. Conclusion 8. Because the parties have resolved the matter and still in need of time to finalize the settlement, it is necessary to extend the time for Appellee to respond to Appellant’s Motion to Stay. D. Prayer 9. For these reasons, Appellee asks the Court to grant an extension of time to file her response to Appellant’s Motion to Stay until July 26, 2015. Respectfully submitted, POTTER BLEDSOE, LLP By: /s/ Gary L. Bledsoe Gary L. Bledsoe State Bar No. 02476500 gbledsoe@potterbledsoe.com Harry G. Potter III hpotter@potterbledsoe.com State Bar No. 16175300 Alondra G. Johnson ajohnson@potterbledsoe.com State Bar No. 24087801 316 W. 12th Street Austin, Texas 78701 (512) 322-9992 Telephone (512) 322-0840 Fax ATTORNEYS FOR APPELLEE CERTIFICATE OF CONFERENCE I certify that on June 26, 2015, my office conferred with Jennifer Powell via email, and she does not oppose Appellee’s Motion to Extend Time to File Response to Appellant’s Motion to Stay. /s/ Gary L. Bledsoe Gary Bledsoe CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on counsel on this 26th day of June 2015, through the Court’s electronic filing system and by electronic mail to the following addresses: Jennifer A. Powell Eichelbaum, Wardell, Hansen, Powell & Mehl, P.C. 4201 Parmer Lane, Suite A100 Austin, Texas 78727 512/476-9944 512/472-2599 fax jpowell@edlaw.com cc:nbn@edlaw.com ATTORNEY FOR APPELLANT /s/ Gary L. Bledsoe Gary Bledsoe