ACCEPTED
14-14-00428-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
1/30/2015 10:59:26 AM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 14-14-00428-CV
§ IN THE FOURTEENTH
FILED IN
IN THE INTEREST OF K.L.S., §
14th COURT OF APPEALS
HOUSTON, TEXAS
A CHILD § COURT OF APPEALS
1/30/2015 10:59:26 AM
§ CHRISTOPHER A. PRINE
§ HOUSTON, TEXAS Clerk
AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT:
Patricia Surovik, Appellee, in the above referenced cause, files this, her Agreed Motion
to Extend Time to File Appellee’s Brief and would respectfully show the Court as follows:
1. This is an Appeal from a cause styled IN the Interest of K.L.S., a child; in the 3121“
District Court of Harris County, Texas.
2. Appellant appealed this cause afier the trial court denied his motion to modify
child support.
3. Appellant timely filed his Notice of Appeal on May 30, 2014.
4. The Clerk’s Record was filed on July 9, 2014.
5. The Reporter’s Record was filed on July 10, 2014.
6. Appellant filed his Brief on October 3, 2014 and Appellee did not receive notice of
the filing. Appellee was made aware that a brief was filed after speaking with Appellant’s
Attorney, Joshua Clover, on January 20, 2015. Appellant’s attorney forwarded a copy’ of the
Appellant’s Brief on January 22, 2015.
7. Appelleerespectfully requests an extension of time of 30 days from January 30, 2015,
in which to file her Brief as she was just notified of the filing of Appellant’s Brief and needs adequate
time to prepare her brief.
8. This is the first extension of time to file her Brief sought by Appellee .
This Motion is not made for purposes of delay, but so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court grant
this motion for an extension of time.
Respectfully submitted,
ADAMS LAW FIRM
23501 Cinco Ranch Blvd «
Ste H205
KATY, TX 77494
£»Q
Tel: (281) 391-9237
Fax: (281)391-0451
Sean R. Jos h lin
State Bar No. 4041215
s1j@1damslawfirm.com
Attorney for Appellee
CERTIFICATE OF CONFERENCE
I certify that
telephone concerning this motion. He indicated that ht‘ with thi ~
on January 20, 2015, I contacted opposing counsel, Joshua S. Clover, by
Sean R. Josephs U
~~
CERTIFICATE OF SERVICE
I certify copy of the above was served on each
that a true
accordance with the Texas Rules of Civil Procedure on
attorn
~ 0 record or party in
“
Sean R. Joseph on