ACCEPTED
01-15-00210-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/10/2015 12:45:05 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00210-CV
FILED IN
1st COURT OF APPEALS
IN THE HOUSTON, TEXAS
6/10/2015 12:45:05 PM
FIRST COURT OF APPEALS CHRISTOPHER A. PRINE
Clerk
HOUSTON, TEXAS
FRANCISCO CALLEJA-AHEDO
Appellant
V.
COMPASS BANK
Appellee
On Appeal from the 55th District Court
Harris County, Texas.
Trial Cause No. 2014-22168
AGREED MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, Appellant Francisco Calleja-Ahedo and files this first motion
for extension of time to file his Appellant’s Brief and would show:
Appellant’s Brief is due on June 11, 2015. This is the first request for extension,
although a prior motion was denied as premature based on the erroneous assumption
that Appellant’s Brief was due earlier. Mr. O’Connor was hospitalized in March for
eight days and underwent three procedures to stabilize his heart. Subsequently, Mr.
O’Connor was again in the hospital for eleven days during the first half of May with
pneumonia and continued heart complications. He still has not been cleared by his
cardiologist and may have to reenter the hospital soon to implant a pacemaker. Mr.
O’Connor is presently restricted in his work and other activities and cannot complete
the brief by June 11, 2015. See doctor’s letter attached hereto. Appellant’s attorneys
have been unable to complete Appellant’s Brief under such circumstances, which
requires dealing with numerous issues and record review.
WHERFORE, Appellant requests a forty-five (45) day extension to file
Appellant’s Brief.
Respectfully submitted,
O'CONNOR, CRAIG, GOULD & EVANS
By: /s/ Michael C. O’Connor
Michael C. O'Connor
State Bar No. 15187000
Lesley C. O’Connor
State Bar No. 24086952
2500 Tanglewilde, Suite 222
Houston, Texas 77063
(713) 266-3311
(713) 953-7513 (Fax)
ATTORNEYS FOR PLAINTIFF
FRANCISCO CALLEJA-AHEDO
CERTIFICATE OF CONFERENCE
The undersigned certifies that he has conferenced by telephone with Michael D.
Conner, attorney for Appellee, who agrees with this Motion.
By: /s/ Michael C. O’Connor
Michael C. O’Connor
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing pleading has been
forwarded to all counsel of record by electronic service or telefax in accordance with
Rule 21a on this 10th day of June, 2015
/s/ Michael C. O’Connor
Michael C. O’ Connor