NHH-Canal Street Apartments, Inc., a Texas Non-Profit Corporation v. Harris County Appraisal District and Harris County Appraisal District Appraisal Review Board ( 2015 )

ACCEPTED 14-14-00251-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 11/25/2015 12:03:02 PM CHRISTOPHER PRINE CLERK NO. 14-14-00251-CV __________________________________________________________________ FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FOURTEENTH DISTRICT OF TEXAS 11/25/2015 12:03:02 PM AT HOUSTON, TEXAS CHRISTOPHER A. PRINE Clerk __________________________________________________________________ NHH-CANAL STREET APARTMENTS, INC., A TEXAS NON-PROFIT CORPORATION Appellant V. HARRIS COUNTY APPRAISAL DISTRICT AND HARRIS COUNTY APPRAISAL DISTRICT APPRAISAL REVIEW BOARD Appellees __________________________________________________________________ On Appeal from the 295TH Judicial District Court of Harris County, Texas; Cause No. 2010-68486 Honorable Caroline E. Baker, Presiding MOTION TO EXTEND TIME TO FILE APPELLEE’S MOTION FOR REHEARING TO THE HONORABLE FOURTEENTH COURT OF APPEALS: Pursuant to Rules 10.5(b) and 49.8 of the Texas Rules of Appellate Procedure, Appellee, Harris County Appraisal District, files this Motion to Extend Time to File Appellee’s Motion for Rehearing, and in support thereof would respectfully show the following: A. Appellee’s Motion for Rehearing is due to be filed on or before Friday, December 4, 2015. B. Appellee requests a 7 day extension of time to file its brief, which, if granted, would make the brief due on or before Friday, December 11, 2015. C. The undersigned will be traveling for the Thanksgiving holiday, as will other attorneys in this firm who have worked on the case. In addition, some constituents of the Appellee are unavailable due to the holiday. D. This extension is requested not for delay, but in order to allow Appellee’s counsel sufficient time to complete the motion. E. This is Appellee’s first request for an extension of time to file this Motion for Rehearing. F. Counsel for Appellant has been contacted and is not opposed to this request, as set forth in the certificate of conference. WHEREFORE, PREMISES CONSIDERED, Appellee respectfully requests that this Court grant this Motion to Extend Time for Filing Appellee’s Motion for Rehearing and set the deadline for filing the motion on Friday, December 11, 2015. 2 Respectfully submitted, OLSON & OLSON, L.L.P. By: /s/ Eric C. Farrar Eric C. Farrar State Bar No. 24036549 efarrar@olsonllp.com Wortham Tower, Suite 600 2727 Allen Parkway Houston, Texas 77019 (713) 533-3800 – Phone (713) 533-3888 – Fax ATTORNEYS FOR APPELLEE HARRIS COUNTY APPRAISAL DISTRICT CERTIFICATE OF CONFERENCE Appellee’s counsel contacted counsel for Appellant on November 24, 2015, and counsel is unopposed to this request to extend time for Appellee to file its Motion for Rehearing. /s/ Eric C. Farrar Eric C. Farrar 3 CERTIFICATE OF SERVICE I hereby certify that on November 24, 2015 a true and correct copy of the foregoing Motion to Extend Time to File Appellee’s Motion for Rehearing was served via: J. Eric Pardue  CMRRR # Pat Mizell  Facsimile No. (713) 758-2346 Glen Rosenbaum  Hand Delivery Vinson & Elkins, LLP  U.S.P.S. 1001 Fannin Street, Suite 2500  E-mail: Houston, Texas 77002-6760  E-Service Gwen J. Samora  CMRRR # The Samora Law Firm  Facsimile No. 4210 Oberlin Street  Hand Delivery Houston, Texas 77005  U.S.P.S.  E-mail:  E-Service /s/ Eric C. Farrar Eric C. Farrar 4