ACCEPTED
01-14-00825-cv
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/20/2015 12:10:06 AM
CHRISTOPHER PRINE
CLERK
01-14-00825-CV
FILED IN
__________________________________ 1st COURT OF APPEALS
HOUSTON, TEXAS
3/20/2015 12:10:06 AM
IN THE
CHRISTOPHER A. PRINE
COURT OF APPEALS FOR THE Clerk
FIRST JUDICIAL DISTRICT OF TEXAS
AT HOUSTON, TEXAS
____________________________________
RAJINDER SINGH AND RITA KAUR, RAJIV CHHABRA AND GAURI
CHHABRA,
APPELLANTS
VS.
SLAWOMIR J. SKIBICKI AND A & SKIPOL, INC., A TEXAS
CORPORATION,
APPELLEES
Appealed from the 11TH DISTRICT COURT of
Harris County, Texas
Trial Court Cause No. 2013-76488
_______________________________________
APPELLANTS’ SECOND MOTION TO EXTEND TIME FOR FILING
APPELLANT’S BRIEF
_______________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW the Appellants, RAJINDER SINGH AND RITA KAUR and
files this their SECOND Motion to Extend Time for Filing Appellant’s Brief and
would respectfully show the following:
1. Appellant’s brief per the courts order is March 20, 2015(30 days after the
later of either the date of the clerk’s record filed or the date of the reporter’s record
filed.)
2. The complete record was filed on February 17, 2015
3. The courts online calendar indicates the deadline was on March 17, 2015.
4. No rule provides a deadline to file this motion to extend. See Tex. R. App.
P. 38.6(d).
5. Although mediation was ordered, neither party has mediated at this time.
6. It is unclear as to the reason the online deadline contradicts the Rules, the
Court’s Order, and the Notice, however Appellants file this motion in abundance
of caution. Appellants respectfully request the deadline for filing their brief be set
for March 20, 2015, which is thirty days for the date the complete record was filed.
7.Contemporaneously with filing this Motion, Appellants are also filing their
Brief.
WHEREFORE PREMISES CONSIDERED, APPELLANTS, RAJINDER
SINGH and RITA KAUR , pray that this Court extend the time in which to file
their Brief and accept Appellants Brief, file contemporaneously with this motion as
timely filed.
Respectfully submitted,
_____________________________
“DANIEL” CHUNG LEE
State Bar No. 24053793
C.Y. Lee Legal Group, PLLC
1305 Prairie St. Ste 300
Houston, Texas 77002
T: (682)551-8506
F: (713)223-0755
cyleelaw@gmail.com
ATTORNEYS FOR Rajinder Singh and
Rita Kaur
CERTIFICATE OF CONFERENCE
Jeremy Roberts, counsel for Appellees who states that he is opposed to this
motion.
Dated this 20th day of March, 2015.
_________________________________
“Daniel” Chung Lee
CERTIFICATE OF SERVICE
I hereby certify that on this date a true and correct copy of the foregoing
document was served upon all parties through their attorneys of record, with
said service being effectuated by the following method:
___ Certified Mail, Return Receipt Requested
___ Telecopy
X Eservice
___ Hand Delivery
___ Regular Mail, Postage Prepaid
Dated this 20th day of March, 2015.
_________________________________
“Daniel” Chung Lee