ACCEPTED
01-15-00243-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/1/2015 12:38:16 PM
CHRISTOPHER PRINE
CLERK
NO . 01-15-00243-CV
__________________________________________ FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE FIRST COURT OF APPEALS
5/1/2015 12:38:16 PM
HOUSTON , TEXAS
CHRISTOPHER A. PRINE
___________________________________________ Clerk
THE DISCOVERY GROUP , INCORPORATED
D /B /A PREFERRED CORPORATE HOUSING
Appellant
V.
RICHARD KAMMEN , INDIVIUDALLY
AND D /B /A RICHARD KAMMEN & ASSOCIATES
Appellee.
___________________________________________
Appeal from the County Civil Court at Law Number Three (3)
Harris County, Texas
Trial Court Cause No. 1029597
___________________________________________
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF
___________________________________________
Andrew P. McCormick
Laurie A. Munoz
McCormick, Lanza & McNeel, LLP
4950 Bissonnet Street
Bellaire, TX 77401
(713) 523-0400
(713) 523-0408 Fax
Attorneys for Appellee,
Richard Kammen, individually and d/b/a
Richard Kammen & Associates
UNOPPOSED MOTION TO EXTEND TIME FOR FILING APPELLEE’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
Richard Kammen, individually and d/b/a Richard Kammen & Associates, Appellee,
moves this court to grant an extension of time to file Appellee's Brief, and respectfully
states:
1. Appellee’s Brief is due to be filed with this Court on May 8, 2015.
2. Appellee, Richard Kammen, individually and d/b/a Richard Kammen &
Associates, seeks a 20-day extension of time to file Appellee's Brief, which would make
Appellee's Brief due on or before May 22, 2015.
3 This extension of time is necessary because due to time constraints and the
time required to conduct the research. It will be difficult for counsel for Appellee, Richard
Kammen, individually and d/b/a Richard Kammen & Associates, to adequately prepare the
brief in this appeal if the extension is not granted. Therefore, additional time is needed to
adequately prepare the arguments in this case.
4. Counsel for Richard Kammen, individually and d/b/a Richard Kammen &
Associates has conferred with the counsel for Appellant, The Discovery Group,
Incorporated d/b/a Preferred Corporate Housing, and he is unopposed to the motion to
extend time.
5. This is the first extension of time Appellee has sought for the filing of the
Appellee's Brief.
2
PRAYER FOR RELIEF
For the reasons set forth above, Appellee requests that this court render an order
extending the time for filing Appellee Richard Kammen, individually and d/b/a Richard
Kammen & Associates’s Brief to and including May 22, 2015. Appellee also requests any
other relief to which it may be entitled.
Respectfully submitted,
MC CORMICK, LANZA & MC NEEL, LLP
By: /s/ Andrew P. McCormick
ANDREW P. McCORMICK
State Bar No. 13457100
amccormick@mlm-lawfirm.com
LAURIE A. MUNOZ
State Bar No. 24071782
lmunoz@mlm-lawfirm.com
4950 Bissonnet Street
Bellaire, Texas 77401
(713) 523-0400 / (713) 523-0408
Attorneys for Appellee
Richard Kammen, individually and d/b/a
Richard Kammen & Associates
CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have
conferred with opposing counsel regarding this request and that Steven D. Poock, counsel
for Appellant, does not oppose this motion.
/s/ Laurie A. Munoz
LAURIE A. MUNOZ
3
CERTIFICATE OF SERVICE
I certify that I have served this document on all other parties, which are listed below
on May 1, 2015 via email and/or facsimile as follows:
Steven D. Poock
Attorney at Law
P. O. Box 984
Sugar Land, TX 77487
/s/ Laurie A. Munoz
LAURIE A. MUNOZ
4
the Discovery Group, Incorporated D/B/A Preferred Corporate Housing v. Richard Kammen, Individually and Dba Richard Kammen & Associates
Combined Opinion