Mark E. Biedryck v. U.S. Bank National Association, as Trustee for Credit Suisse, First Boston Mortgage Securities Corp., Home Equity Pass-Through Certificates, Series 2005-6

ACCEPTED 01-14-00017-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 5/22/2015 5:12:08 PM CHRISTOPHER PRINE CLERK NO. 01-14-00017-CV FILED IN 1st COURT OF APPEALS In the Court of Appeals HOUSTON, TEXAS for the First Judicial District of 5/22/2015 5:12:08 PM Texas at Houston CHRISTOPHER A. PRINE Clerk Mark E. Biedryck, Appellant v. US Bank National Association, as Trustee for Credit Suisse, First Boston Mortgage Securities Corp., Home Equity Pass- Through Certificates, Series 2005-6, Appellee Appeal from the 129th Judicial District Harris County, Texas Hon. Michael Gomez APPELLANT’S MOTION TO EXTEND TIME TO FILE MOTION FOR REHEARING TO THE HONORABLE COURT OF APPEALS: Appellant Mark E. Biedryck seeks an extension of time to file a Motion For Rehearing. 1. In compliance with Rule10.5(b)(1): (A) The current deadline set for filing a Motion For Rehearing is May 27, 2015; (B) The extension sought is 30 days; (C) Appellant’s counsel is a solo practitioner whose caseload, which consists primarily of representing reduced-fee and pro bono clients in foreclosure and facing eviction, prevents him from being able to file the Motion by the current deadline. (D) There have been no prior extensions granted with respect to the item in question. PRAYER WHEREFORE, the Appellant prays that the deadline for filing a Motion For Reconsideration be extended at least 30 days and that he be granted such other and further relief to which he may be entitled to at law or in equity. Respectfully submitted, /s/ Ira D. Joffe Ira D. Joffe State Bar No. 10669900 Attorney for Appellant 6750 West Loop South Suite 920 Bellaire, TX 77401 (713) 661-9898 (888) 335-1060 Fax ira.joffe@gmail.com CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was served by fax and/or email to Appellee’s counsel on or before May 22, 2015. (713) 223-3717; kkrolikowski@lockelord.com Mr. Kurt Krolikowski, Esq. Locke Lord, LLP Counsel for Appellee 600 Travis, Suite 2800 Houston, TX 77002 /s/ Ira Joffe