the City of Laredo v. Northtown Development, Inc. and Gateway Centennial Development, Co. ( 2015 )

ACCEPTED 04-15-00736-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 11/30/2015 4:47:57 PM KEITH HOTTLE CLERK CAUSE NO. 04-15-00736-CV *** FILED IN 4th COURT OF APPEALS IN THE COURT OF APPEALS SAN ANTONIO, TEXAS 11/30/15 4:47:57 PM FOURTH COURT OF APPEALS DISTRICT KEITH E. HOTTLE SAN ANTONIO, TEXAS Clerk *** CITY OF LAREDO, TEXAS Appellant, V. NORTHTOWN DEVELOPMENT, INC. & GATEWAY CENTENNIAL DEVELOPMENT, CO. (Successors-In-Interest to Trautmann Investment Properties, Ltd.) Appellees APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF LAW OFFICES OF RYAN HENRY, PLLC Ryan S. Henry State Bar No. 24007347 Artin T. DerOhanian State Bar No. 24095346 1380 Pantheon Way, Suite 110 San Antonio, Texas 78232 210-257-6357 (Telephone) 210-569-6494 (Facsimile) Ryan.Henry@rshlawfirm.com Artin.DerOhanian@rshlawfirm.com ATTORNEYS FOR APPELLANT 1 TO THE HONORABLE JUDGE OF SAID COURT: Appellant, CITY OF LAREDO, TEXAS (hereinafter “City”), files this its First Motion for Extension of Time to File Brief and shows the Court as follows: The Appellant City filed this appeal on November 20, 2015 due to the judge in the 111th District Court of Webb County denying its Plea to the Jurisdiction. The court has listed the brief due on December 15, 2015. Due to the coming holidays putting several business days on hold, Appellant requests a 30 day extension of the brief deadline making the due date January 15, 2016. I have consulted with the attorneys for the Appellees and they are unopposed to the relief sought in this motion to extend deadline. Appellant City prays this court grant this first motion for extension and extend the briefing deadline to January 14, 2016. The City further requests what other relief it may be entitled to regarding this motion. 2