Reagan National Advertising of Austin, Inc. v. City of Austin and Greg Guernsey, in His Official Capacity as Director of Planning and Development Review

ACCEPTED 07-15-00028-CV

SEVENTH COURT OF APPEALS

AMARILLO, TEXAS 2/26/2015 9:28:11 AM

Vivian Long, Clerk

NO. 07-15-00028-CV

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FILED IN IN THE COURT OF APPEALS 7th COURT OF APPEALS

FOR THE SEVENTH DISTRICT OF TEXAS AMARILLO, TEXAS POTTER COUNTY, AMARILLO, TEXAS 2/26/2015 9:28:11 AM

VIVIAN LONG ________________________________________________________________________

CLERK REAGAN NATIONAL ADVERTISING OF AUSTIN, INC., APPELLANT

VS. THE CITY OF AUSTIN AND GREG GUERNSEY, IN HIS OFFICIAL CAPACITY AS

DIRECTOR OF PLANNING AND DEVELOPMENT REVIEW, APPELLEES ________________________________________________________________________

ON APPEAL FROM th THE 250 JUDICIAL DISTRICT COURT TRAVIS COUNTY, TEXAS CAUSE NO. D-1-GN-13-002477

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APPELLANT’S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME ________________________________________________________________________

Appellant Reagan National Advertising of Austin files this motion, which is unopposed, seeking a 30-day extension of the deadline for its Appellant’s Brief.

1. The deadline for Appellant’s Brief is currently Wednesday, March 4, 2015. 2. Appellant requests a 30-day extension until Friday, April 3, 2015. This is

Appellant’s first request for an extension.

3. The additional time is sought due to recent and unexpected demands on counsel’s time in other matters, the deadlines for which could not be extended by agreement.

4. Appellees do not oppose the relief requested in this motion. 5. This extension is not sought for delay, but so that justice may be done. For these reasons, Appellant prays that the Court grant an extension of its deadline to file the Appellant’s Brief until April 3, 2015.

Respectfully submitted, /s/ B. Russell Horton B. Russell Horton State Bar No. 10014450 [email protected] George Brothers Kincaid & Horton, L.L.P. 114 West 7th Street, Suite 1100 Austin, Texas 78701 (512) 495-1400 (512) 499-0094 FACSIMILE ATTORNEY FOR APPELLANT

CERTIFICATE OF CONFERENCE

I spoke with Chris Coppola on February 25, 2015. He indicated that Appellees do not oppose relief requested in this motion.

/s/ B. Russell Horton B. Russell Horton

CERTIFICATE OF SERVICE

The undersigned certifies that a copy of this brief was served on February 26, 2015, on the following by email and through the court’s e-filing system: Karen M. Kennard Meghan L. Riley Christopher Coppola City of Austin-Law Department PO Box 1546 Austin, TX 78767-1546 512-974-1311 (facsimile) [email protected]

/s/ B. Russell Horton B. Russell Horton