Manor Independent School District v. Deydra Steans ( 2015 )

ACCEPTED
03-15-00294-CV
5431844
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/27/2015 12:12:05 PM
JEFFREY D. KYLE
CLERK
CAUSE NO. D-1-GN-13-000241
DEYDRA STEANS § IN THE DISTRICT COURT
Petitioner § FILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
V. § OF TRAVIS COUNTY, TEXAS
5/27/2015 12:12:05 PM
§ JEFFREY D. KYLE
MANOR INDEPENDENT § Clerk
SCHOOL DISTRICT §
Defendant §
§
§ 200th JUDICIAL
DISTRICT
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 brief.
A. Introduction
1. Appellant is Manor Independent School District.
2. Appellee is Deydra Steans.
3. The deadline to file this response is May 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
the brief.
6. Appellee requests an additional 30 days to file her brief.
7. No extension has been granted to extend the time to file Appellee’s brief.
8. Appellant needs additional time because the parties have 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 attempting to finalize a settlement agreement.
C. Conclusion
9. Because the parties have resolved the matter and need time to finalize a
settlement it is necessary to extend the time for the response to the
outstanding motion.
D. Prayer
10. For these reasons Appellee asks the Court to grant an extension of time to file
her brief until June 26th, 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 Johnson
ajohnson@potterbledsoe.com
State Bar No. 24087801
316 W. 12th Street
Austin, Texas 78701
(512) 322-9992 Telephone
(512) 322-0840 Fax
CERTIFICATE OF CONFERENCE
I certify that I have conferred with Jennifer Powell by telephone and e-mail
and she has agreed and is unopposed to Appellee’s Motion to Extend Time to File A
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 instrument has
been forwarded to the following parties via e-mail/e-service, United States certified
mail and/or via facsimile on this 26th day of May 2015.
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
Attorneys for Defendant
/s/ Gary L. Bledsoe
Gary Bledsoe