ACCEPTED
01-14-01014-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/1/2015 2:12:04 PM
CHRISTOPHER PRINE
CLERK
No.01-14-01014-CV
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURTOF ApPEALS 4/1/2015 2:12:04 PM
FOR THEFIRST DISTRICTOFTEXAS CHRISTOPHER A. PRINE
AT HOUSTON Clerk
LETICIALoy A,
Appellant,
v.
IANTAYLOR,JACOBUSSTERKEN,STICHTINGTINSELGROUP,VITOL
HOLDINGII S.A., AND TINSELGROUP,S.A.,
Appellees.
Appeal from the 190th Judicial District Court, Harris County, Texas
Trial Court Cause No. 2012-33464
UNOPPOSED FIRST MOTION TO EXTEND
TIME FOR FILING APPELLANT'S REPLY BRIEF
TO THE HONORABLE FIRST COURT OF APPEALS:
LETICIA LoyA, Appellant, moves this Court to grant an extension of
time to file Appellant's Reply Brief, and respectfully states:
1. Appellant's Reply Brief is due to be filed with this court on April 14,
2015.
2. Appellant seeks a 20-day day extension of time to file Appellant's Brief,
which would make Appellant's Brief due on or before May 4,2015.
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3. This extension of time is necessary because lead counsel for Appellant
was/is participating in several oral arguments, appeals and/or trials with
deadlines prior to April 14, 2015 deadline, including but not limited to:
• Universal Gold Coin v. FedEx et al, Western District of Tennessee
(Daubert and pre-trial motions)
• Filer v. Keystone Corporation, New York State Supreme Court,
(pretrial motions and hearings)
• Altamirano v. KONE, 136th Judicial District of Texas (eleven
depositions, discovery deadline approaching)
• Raja v. Kolander, 172nd Judicial District of Texas (trial)
• Reado v. Lopez, 136th Judicial District of Texas (trial)
As a result, time constraints will make it difficult to adequately prepare the
reply brief in this appeal. This request is not filed for the purpose of delay,
but rather to afford counsel adequate time to prepare the brief. Therefore,
additional time is needed to adequately prepare the arguments in this case.
4. Counsel for Appellant has conferred with counsel for Appellees Ian
Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and
Tinsel Group, S.A., and Appellees do not oppose this motion to extend time.
5. This is the first extension of time Appellant has sought for the filing of
the Appellant's Reply Brief.
For these reasons, LETICIA Loy A, Appellant, requests that this Court
render an order extending the time for filing Appellant's Reply Brief to and
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including May 4, 2015. Appellant also requests any other relief to which she
may be entitled.
Respectfully submitted,
PROVOST *UMPHREY LAW FIRM,
L.L.P.
490 Park Street
P. O. Box 4905
Beaumont, Texas 77704
(409) 835-6000
(409) 813-8682 (FAX)
By: / s / Jenniter Job
Jennifer Job
Texas State Bar No. 24050682
James Payne
Texas State Bar No. 00788171
ATTORNEYS FOR APPELLANT
CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with counsel for Appellees Ian Taylor,
Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and Tinsel
Group, S.A. concerning this motion, and Appellees do not oppose the relief
requested in this motion.
/ s / Jennifer Job
CERTIFICATEOF SERVICE
I hereby certify that a copy of this motion to amend notice of appeal
has been sent to all known counsel of record via EFILE and/or certified
mail, return receipt requested on April 1, 2015.
/ s / Jennifer Job
Jennifer Job
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