Toby Paul Couchman and Pro-Surv v. Elizabeth Cardona

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ACCEPTED 01-14-01000-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 5/20/2015 6:05:41 PM CHRISTOPHER PRINE CLERK No. 01-14-01000-CV FILED IN 1st COURT OF APPEALS In The HOUSTON, TEXAS 5/20/2015 6:05:41 PM COURT OF APPEALS CHRISTOPHER A. PRINE Clerk FIRST DISTRICT OF TEXAS Houston, Texas TOBY PAUL COUCHMAN AND PRO-SURV, Appellants, v. ELIZABETH CARDONA, Appellee. On Appeal from Case No. 2014-29414 In the 189th District Court of Harris County, Texas Honorable William R. Burke, Presiding Judge UNOPPOSED MOTION REQUESTING RESET OF TIME FOR ORAL ARGUMENT TO THE HONORABLE FIRST COURT OF APPEALS: Appellants Toby Paul Couchman and Pro-Surv file this Unopposed Motion Requesting Reset of Time for Oral Argument. The Court has scheduled Oral Argument for Tuesday June 9, 2015 at 10:30 a.m. Appellants’ lead appellate counsel, Andrew Johnson, has previously committed to making a CLE presentation on June 9, 2015 at 12:00 p.m. (noon). In order to allow sufficient time following 2119935v1 05060.795 oral argument for Mr. Johnson to arrive at the CLE location, Appellants request that oral argument be reset for 10:00 a.m. on June 9, 2015. Counsel for Appellee Elizabeth Cardona is unopposed to this request. If resetting argument to 10:00 a.m. does not work with the Justices’ schedule, Appellants are also amenable to having oral argument reset for another time or date. PRAYER For the foregoing reasons, Appellants Toby Paul Couchman and Pro-Surv ask that the time for oral argument be reset for 10:00 a.m. on June 9, 2015, and for any other relief in law or equity to which they are entitled. Respectfully submitted, By: /s/ Andrew L. Johnson______ Zandra E. Foley State Bar No. 24032085 Andrew L. Johnson State Bar No. 24060025 Kimberly R. Snagg State Bar No. 24075099 One Riverway, Suite 1400 Houston, Texas 77056 T: (713) 403-8210 | F: (713) 403-8299 Email: zfoley@thompsoncoe.com Email: ajohnson@thompsoncoe.com Email: ksnagg@thompsoncoe.com ATTORNEYS FOR APPELLANTS -2- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was sent pursuant to the Rules on May 20, 2015, to the following: Robert L. Collins Audrey Guthrie P O Box 7726 Houston, Texas 77270 Christopher D. Lewis 1721 West T.C. Jester Blvd., Houston, Texas 77008 Attorney for Plaintiffs        /s/ Andrew L. Johnson ANDREW L. JOHNSON CERTIFICATE OF CONFERENCE On May 20, 2015, I conferred with Mr. Christopher D. Lewis, counsel for Appellee Elizabeth Cardona, who indicated Appellee is unopposed to resetting oral argument to 10:00 a.m. on June 9, 2015.        /s/ Andrew L. Johnson ANDREW L. JOHNSON -3-