Lazaro Walck v. the City of Lubbock ( 2017 )


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  •                                                                                                ACCEPTED
    07-17-00096-CV
    SEVENTH COURT OF APPEALS
    AMARILLO, TEXAS
    8/14/2017 3:46 PM
    Vivian Long, Clerk
    NO. 07-17-00096-CV
    FILED IN
    7th COURT OF APPEALS
    IN THE                             AMARILLO, TEXAS
    SEVENTH COURT OF APPEALS                  8/14/2017 3:46:59 PM
    AMARILLO, TEXAS                            VIVIAN LONG
    CLERK
    LAZARO WALCK
    Appellant,
    V
    CITY OF LUBBOCK
    Appellee.
    On Appeal from the 72nd District Court of Lubbock County, Texas, Lazaro Walck
    v. City of Lubbock, Cause No. 2014-509,907
    UNOPPOSED MOTION TO EXTEND TIME
    FOR FILING APPELLEE’S BRIEF
    TO THE HONORABLE COURT OF APPEALS:
    COMES NOW, CITY OF LUBBOCK, Appellee, and moves this Honorable
    Court to grant a thirty (30) day extension of time to file Appellee’s Brief, and would
    respectfully show as follows:
    1.     The City of Lubbock’s Brief is due to be filed with this Court on August
    28, 2017.
    2.   City of Lubbock seeks a 30 day extension of time to file it’s Brief,
    which would make the Brief due on September 28, 2017.
    3.   This requested extension is requested as counsel for the City of
    Lubbock is preparing briefs in other cases that are due on August 25, 2017 and
    September 8, 2017, in which there are unique issues of law that require extensive
    briefing and research. As such, counsel does not believe that he will have sufficient
    time before August 28, 2017, to properly prepare the brief on the issues that will be
    presented in this appeal.
    4.   Counsel for the City has conferred with counsel for Lazaro Walck and
    he does not oppose this extension.
    5.   This is the first extension of time that the City of Lubbock has sought
    for the filing of its Brief, and this request for extension is not sought for delay, but
    in order that justice might be done.
    For these reasons, CITY OF LUBBOCK requests that this Court grant this
    motion, and render an order extending the time for filing its Brief to September 28,
    2017.
    Respectfully submitted,
    JEFF HARTSELL
    Assistant City Attorney
    State Bar No. 09170275
    P O Box 2000
    Lubbock, Texas 79457
    806-775-2222
    Fax 806-775-3307
    Email: jhartsell@mylubbock.us
    /s/ Jeff Hartsell
    JEFF HARTSELL
    CERTIFICATE OF CONFERENCE
    THIS IS TO CERTIFY that the undersigned counsel for Appellee CITY OF
    LUBBOCK, has conferred with counsel for Appellant, Phil Johnson, regarding this
    motion and he does not oppose this motion.
    /s/ Jeff Hartsell
    JEFF HARTSELL
    CERTIFICATE OF SERVICE
    I hereby certify that on the 14th day of August, 2017, I electronically filed the
    foregoing document with the Seventh Court of Appeals using an e-filing service
    provider. The electronic filing system sent a “Notification of Service” to the
    following by electronic means.
    Phil A. Johnson
    Jenkins, Wagnon & Young, P.C.
    P O Box 420
    Lubbock, Texas 79408
    pjohnson@jwylaw.com
    /S/ Jeff Hartsell
    JEFF HARTSELL
    

Document Info

Docket Number: 07-17-00096-CV

Filed Date: 8/14/2017

Precedential Status: Precedential

Modified Date: 11/17/2017