Cecil Adams and Maxine Adams v. Harris County and Christopher A. Prine, Clerk of the First Court of Appeals ( 2015 )

ACCEPTED
04-15-00287-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
7/2/2015 5:05:22 PM
KEITH HOTTLE
CLERK
No. 04-15-00287-CV
______________________________
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
07/2/2015 5:05:22 PM
FOR THE FOURTH JUDICIAL DISTRICT KEITH E. HOTTLE
Clerk
SAN ANTONIO, TEXAS
______________________________
Cecil and Maxine Adams,
Plaintiffs - Appellants,
vs.
Harris County, Rebecca Ross, Kathleen Keese and
Christopher Prine, Clerk of the First Court of Appeals,
Defendants - Appellees.
______________________________
On Appeal from the 269th District Court of Harris County, Texas
Trial Court Cause No. 2014-35653
APPELLEES’ JOINT MOTION FOR EXTENSION OF
TIME TO FILE RESPONSE BRIEF
TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF
APPEALS:
Defendant-Appellees Harris County and Christopher Prine, District Clerk for
the First Court of Appeals, move for a 20-day extension of time to file their briefs in
response to Plaintiff-Appellant Adams= brief. This is the first extension sought by
Appellees in this interlocutory appeal. Further, Appellants were afforded an
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extension of time to file their brief.
Currently, Appellees’ briefs are due on July 9, 2015. The undersigned
contend that the need for an extension is not due to sloth or neglect, and is not
requested for the purpose of delay. An extension is requested so that counsel may
have adequate time to review the clerk and reporters records, their own records, and
file thorough briefs, thereby preserving judicial economy. Therefore, Appellees
respectfully request a 20-day extension to file Appellees’ briefs.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
CHARLES E. ROY
First Assistant Attorney General
JAMES E. DAVIS
Deputy Attorney General for Civil
Litigation
KAREN D. MATLOCK
Assistant Attorney General
Chief, Law Enforcement Defense Division
/s/ Christin Cobe Vasquez
CHRISTIN COBE VASQUEZ
Assistant Attorney General
State Bar No. 24074047
Christin.vasquez@texasattorneygeneral.gov
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P.O. Box 12548, Capitol Station
Austin, Texas 78711
(512) 463-2080 / Fax (512) 936-2109
ATTORNEYS FOR DEFENDANT-
APPELLEE CHRISTOPHER PRINE
-AND-
/s/ Keith A. Toler
KEITH A. TOLER
Assistant County Attorney
State Bar No. 24088541
1019 Congress, 15th Floor
Houston, Texas, 77002
Phone: (713) 274-5265
Fax: (713) 755-8924
Email: Keith.Toler@cao.hctx.net
ATTORNEY FOR APPELLEE HARRIS
COUNTY
CERTIFICATE OF CONFERENCE
I, KEITH A. TOLER, attempted to confer with Appellants via email
regarding the substance of this motion on Wednesday, July 1, 2015; however, as of
the time of filing this motion I did not receive any response. Therefore, it must be
assumed that Appellants oppose this motion.
/s/ Keith Toler
KEITH TOLER
Assistant County Attorney
CERTIFICATE OF SERVICE
I, CHRISTIN COBE VASQUEZ, Assistant Attorney General of Texas,
certify that a true copy of Appellees’ Joint Motion for Extension of Time to File
Response Brief was served upon all counsel of record via electronic filing
notification, email and/or FedEx Overnight, return receipt requested, on July 2,
2015, addressed to:
Jayson Booth Maxine Adams FedEx Overnight
ATTORNEY FOR KATHLEEN Cecil Adams
KEESE 5510 South Rice # 1206
3730 Kirby Drive, Ste 777 Houston, TX 77081
Houston, TX 77098 PRO SE
(p) 713.280.9312 Cecillovesmax@sbcglobal.net
(f) 713.526.1175 Swayne.adams@yahoo.com
Email: info@boothricheylaw.com
Brian A. Quintero Timothy Henderon
Keith A. Toler COUNSEL FOR REBECCA ROSS
ASST. COUNTY ATTORNEY 6300 West Loop South, Ste 280
1019 Congress 1th Floor Houston, TX 77401
Houston, TX 77002 (f) 713.688.5697
Brian.Quintero@cao.hctx.net timjhenderson@msn.com
Keith.toler@cao.hctx.net
Clinton Gambill
ASST. COUNTY ATTORNEY
1019 Congress 1th Floor
Houston, TX 77002
(p)713-755-5101
(f)713-755-8924
Clinton.Gambill@cao.hctx.net
/s/ Christin Cobe Vasquez
Christin Cobe Vasquez
Assistant Attorney General
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NOTICE OF ELECTRONIC FILING
I, CHRISTIN COBE VASQUEZ, Assistant Attorney General of Texas,
certify that I have electronically submitted the foregoing motion for filing in
accordance with the Electronic File and Serve System for the Fourth Court of
Appeals on July 2, 2015.
/s/ Christin Cobe Vasquez
Christin Cobe Vasquez
Assistant Attorney General
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