ACCEPTED
01-14-00724-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/9/2015 2:34:14 PM
CHRISTOPHER PRINE
CLERK
IN THE
FIRST COURT OF APPEALS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
1/9/2015 2:34:14 PM
______________________________ CHRISTOPHER A. PRINE
Clerk
NO. 01-14-00724-CV
_____________________________
RONNY PUGA AND RICKEY PUGA, Appellants
v.
BARBARA SALESI, Appellee
_________________________
On Appeal from the 133rd Judicial District Court
of Harris County, Texas
Trial Court Cause No. 2011-28575
__________________________________________
Richard L. Petronella
Petronella Law Firm, P.C.
SBN 15852000
2421 Tangley, Suite 116
Houston, Texas 77005
Phone 713.965.0606
Fax 713.965.0676
Email richard@petronellalawfirm.com
Appellants’ Attorney
APPELLANTS’ FIRST MOTION
TO EXTEND TIME TO FILE APPELLANTS’ BRIEF
COMES NOW RONNY PUGA AND RICKEY PUGA, Appellants,
and file this First Motion to File Appellants’ Brief.
1. Appellants filed this appeal on August 29, 2014.
2. On October 10, 2014, the Clerk’s Record was filed with this
Court.
3. On December 16, 2014, the Court Reporter’s Record was filed
with this Court.
4. On December 22, 2014, the Court Reporter’s Supplemental
Record was filed with this Court which contained the record of the second
day of a three day trial in the trial court and most of the relevant evidence.
5. The Appellants’ Brief is now due on January 15, 2015.
6. This is the Appellants’ first motion to extend the time to file
Appellants’ Brief.
7. Appellants’ appellate counsel was not Appellants’ trial counsel
so he was not already familiar with the facts and legal issues below but he
has been diligently reviewing the record below to prepare Appellants’ Brief.
There is not sufficient time before January 15, 2015, for Appellants to
adequately prepare their brief. Now, after review of the record below,
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Appellants’ will request the trial court clerk by letter to supplement the
Clerk’s Record with matters Appellants believe relevant to this appeal.
8. Appellants respectfully request that this Court grant Appellants
a 30 day extension to file Appellants’ Brief.
9. Certificate of Conference. Counsel for Appellants has
conferred with counsel for Appellee, BARBARA SALESI, now the
ESTATE OF BARBARA SALESI, DECEASED, regards this motion, and
this motion is opposed.
Wherefore, premises considered, Appellants respectfully request that
the deadline to file Appellants’ Brief be extended to February 16, 2015.
Respectfully submitted,
PETRONELLA LAW FIRM, P.C.
[s] Richard L. Petronella
Richard L. Petronella
SBN 15852000
2421 Tangley, Suite 116
Houston, Texas 77005
Phone 713.965.0606
Fax 713.965.0676
richard@petronellalawfirm.com
Attorney for Appellants
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CERTIFICATE OF SERVICE
I, the undersigned, do hereby certify that I served counsel for
Appellee with this pleading by electronic service on January 9, 2015 to:
Dax Faubus
Courtney Culver
1001 Texas Avenue, 11th Floor
Houston, Texas 77002
Counsel for Appellee
[s] Richard L. Petronella
Richard L. Petronella
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