ACCEPTED 14-14-00932-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/3/2015 12:55:45 PM CHRISTOPHER PRINE CLERK No. 14-14-00899-CV No. 14-14-00932-CV FILED IN Mayor Annise Parker and 14th COURT OF APPEALS HOUSTON, TEXAS City of Houston, 3/3/2015 12:55:45 PM Appellants, CHRISTOPHER A. PRINE Fourteenth Court of Appeals Clerk v. Houston, Texas Jack Pidgeon and Larry Hicks, Appellees.

Appellees’ Motion to Extend Deadline to File Brief The Appellees ask the Court to extend their deadline to file their brief in these cases through March 13, 2015. This would be their se- cond extension in the ’899 case (in which the current deadline is Feb- ruary 27) and their first extension in the ’932 case (in which the cur- rent deadline is February 17).

The Appellees are, simultaneously with this motion, asking the Court to allow them to supplement the record with materials from previous iterations of this case. Part of that requested supplement is a transcript of a December 20, 2013, hearing conducted before the trial court in the previous iteration of this case. They haven’t yet received that transcript. They cannot finalize their briefs without it. They ex- pect to receive the transcript this week, but they request a longer ex- tension to make it less likely that they will have to come to the Court seeking leave again.

There is additional good cause for the extension in both cases: The Appellees’ lead appellate counsel was incapacitated for several days due to back spasms and was unable to work on the brief. Further, due to the overlap in time periods, the delays and obligations described in the Appellees’ motion for extension in the ’899 case are good cause for an extension in the ’932 case.

This extension won’t prejudice the appellants. They also received 30-day extensions on the deadlines for their briefs in both cases, and the rulings below are stayed by operation of law because the appellants are a Texas government and a mayor acting in her official capacity.

The Appellees pray that the Court extend their deadline to file their brief through March 13. They further pray for all other relief to which they may be entitled.

Respectfully submitted, The Olson Firm PLLC /s/ Leif A. Olson Leif A. Olson Texas Bar No. 24032801 [email protected] PMB 188 4830 Wilson Road, Suite 300 Humble, Texas 77396 (281) 849-8382 Woodfill Law Firm, P.C.

Jared R. Woodfill State Bar No. 00788715 No. 14-14-00899-CV; No. 14-14-00932-CV, Parker v. Pidgeon Page 2 Appellees’ Motion to Extend Deadline to File Brief [email protected] Robert Talton State Bar No. 19629800 [email protected] 3131 Eastside, Suite 450 Houston, Texas 77098 (713) 751-3080 Texas Values Jonathan M. Saenz State Bar No. 24041845 [email protected] Congress, Suite 220 Austin, Texas 78701 Counsel for appellees Certificate of Conference I conferred with Kate Alsina, counsel for the appellants, regarding this motion. She informed me that the appellants oppose this motion to the extent that the requested extension is based on the absent tran- script and the simultaneous request to supplement the record. /s/ Leif A. Olson Certificate of Service On March 3, 2015, I served this motion upon the appellants’ coun- sel by electronic filing: Judith Ramsey ([email protected]) Kathleen Hopkins Alsina ([email protected]) Darah Eckert ([email protected]) David Red ([email protected]) John Wallace ([email protected]) City of Houston Legal Department Bagby, Fourth Floor Houston, Texas 77002 /s/ Leif A. Olson No. 14-14-00899-CV; No. 14-14-00932-CV, Parker v. Pidgeon Page 3 Appellees’ Motion to Extend Deadline to File Brief