Sandra Nze v. Uchenna Nwabueze

ACCEPTED 01-14-01015-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/8/2015 3:31:14 PM CHRISTOPHER PRINE CLERK No. 01-14-01015-CV FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS FOR THE FIRST DISTRICT HOUSTON, TEXAS HOUSTON, TEXAS 4/8/2015 3:31:14 PM CHRISTOPHER A. PRINE Clerk SANDRA NZE Appellant V. UCHENNA NWABUEZE Appellee _____________________________________________________________________________ APPELLEE’S SECOND RESPONSE IN OPPOSITION TO APPELLANT’S SECOND REQUEST FOR AN EXTENSION Comes Now the Appellee, Uchenna Nwabueze, by and through his attorney of record, and presents this Second Response in Opposition to Appellant’s Second Request for an Extension and in support of said Motion, Appellee would show the court the following: 1. This is an appeal from an eviction case wherein Appellant was ordered by the Justice Court to vacate the premises in question. The County Court, on appeal, affirmed the Justice Court’s ruling and ordered Appellant to vacate the premises on or before December 31, 2014. 2. This is Appellant’s second request for an extension. She filed a request, on her own, for an extension, in March 2015, and now in April 2015 has retained the services of an attorney who is also filing a request for an extension. The attorney’s reasons for the extension is that council has “previously scheduled depositions through April 28, 2015.” 3. Appellant’s constant request for extensions appear to be a clever way to continue to manipulate the judicial system, and is an overt strategy to continue to reside in a residence that she is not lawfully entitled to be in. She has successfully managed to reside in the residence without paying any rent for close to a year. Appellant has now retained the services of an attorney who is requesting an extension because she is too busy to prepare a brief for this appeal. Appellee continues to suffer enormous financial hardship at the expense of the Appellant’s continued manipulation and abuse of the appeal process. While this appeal is pending Appellant continues to occupy the residence and not pay any rent or costs to Appellee. Any additional delays or extensions in this appeal will compound the enormous financial hardship that Appellee is experiencing. Appellant’s request for an extension appears to be for no other reason other than to delay, and to continue residing in the residence free of cost, not paying any rent for as long as possible. Therefore, Appellee requests that Appellant’s Second Request for an Extension be denied. Respectfully submitted, WHITE LAW OFFICE BY: ___ s/ Carlettte White Carlette White, P.O. Box Sugar Land, Texas 77487 TBN: 21516430 281-203-0800 713-391-8724 fax Whitelawoffice1@aol.com ATTORNEY FOR APPELLEE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been furnished by VIA email to Appellant’s Attorney of Record on this 8th day of April, 2015. BY: ___/s/ Carlettte White____________ Carlette White, Attorney for Plaintiff 2