Ali Lahijani and Mega Shipping, LLC v. Melifera Partners, LLC, MW Realty Group, and Melissa Walters

ACCEPTED 01-14-01025-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/24/2015 6:01:04 PM CHRISTOPHER PRINE CLERK APPEAL NO. 01-14-01025-CV FILED IN 1st COURT OF APPEALS IN THE HOUSTON, TEXAS 4/24/2015 6:01:04 PM FIRST COURT OF APPEALS CHRISTOPHER A. PRINE Clerk AT HOUSTON, TEXAS ALI LAHIJANI AND MEGA SHIPPING, LLC Appellants, v. MELIFERA PARTNERS, LLC, MW REALTY GROUP and MELISSA WALTERS Appellees Appealed From the 157th Judicial District Court of Harris County, Texas Trial Court Cause No. 2014-60091 APPELLEES’ MOTION TO EXTEND TIME TO FILE BRIEF __________________________________________________________________ U. Lawrence Boze’ State Bar of Texas No.02801600 Bozelaw@aol.com U. Lawrence Boze’& Associates, P.C. 2212 Blodgett Houston, Texas 77004 (713) 520-0260 Office Telephone (713) 520-6194 Fax ATTORNEY FOR APPELLEES APPEAL NO. 01-14-01025-CV IN THE FIRST COURT OF APPEALS AT HOUSTON, TEXAS ALI LAHIJANI AND MEGA SHIPPING, LLC Appellants, v. MELIFERA PARTNERS, LLC, MW REALTY GROUP and MELISSA WALTERS Appellees Appealed From the 157th Judicial District Court of Harris County, Texas Trial Court Cause No. 2014-60091 APPELLEES’ MOTION TO EXTEND TIME TO FILE BRIEF __________________________________________________________________ TO THE HONORABLE FIRST COURT OF APPEALS: COME NOW, Melifera Partners, LLC;MW Reality Group, and Melissa Walters, Appellees in the above styled and numbered appeal now pending before this Appeals Court, and move, pursuant to Rule 10.5(b)(1)of the Texas Rules of Appellant Procedure, for an extension of time to file Appellees’ Brief and would respectfully show this Appeals Court as follows: 1 .Appellees’ Brief is now due to be filed on or before May 4, 2015. Appellees respectfully move for an extension of time to file Appellees’ Brief in order to have adequate and sufficient time to adequately and completely respond to Appellants’ Opening Brief which is more than thirty-five pages in length with an Appendix and that cites forty-one (41) Texas cases and twenty (20) Texas statutes in support. 2. Appellees request an extension of time of twenty-eight (28) days, i.e., until June 1, 2015, to file Appellees’ Brief. 3. This is Appellees first request for an extension of time to file Appellees’ Brief and this request is not being made for purposes of delay but in the interest of justice and fairness to all parties particularly since Appellees, through their undersigned lead attorney in charge, did not oppose the extension of time that was sought by Appellants through their attorneys of record to file Appellants’ Brief which was granted by this Appeals Court. WHEREFORE, for reasons stated herein, Appellees pray that this Appeals Court consider Appellees ‘Motion For An Extension Of Time To File Appellees ‘Brief and grant Appellees an extension of time of twenty-eight(28) days ,i.e., until June 1,2015, to file Appellees’ Brief. Respectfully submitted, U. LAWRENCE BOZE’ & ASSOCIATES, P.C. /s/ U.Lawrence Boze’ _________________ U. Lawrence Boze’ SBOT No: 02801600 2212 Blodgett Houston, Texas 77004 (713) 520-0260 Office Telephone (713) 520-6194 Fax Lead Attorney In Charge For Appellees CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing pleading was forwarded to Appellants by and through their attorneys of record by electronic filing on this __24th_______ day of April, 2015. /s/ U.Lawrence Boze’ ___________________________ U. Lawrence Boze’ CERTIFICATE OF CONFERENCE This is to certify that on April 24, 2015, I spoke with Ciro J. Samperi, one of the attorneys of record for Appellants in this appeal and on behalf of Appellants he indicated that Appellants do not oppose Appellees ‘Motion For An Extension Of Time To File Appellees ‘Brief. /s/ U.Lawrence Boze’ ___________________________ U. Lawrence Boze’