Nationwide Distribution Services, Inc. v. Robert Jones and Poly Trucking, Inc.

ACCEPTED 01-15-00232-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 6/25/2015 11:22:33 AM CHRISTOPHER PRINE CLERK CAUSE NO. 01-15-00232-CV ________________________________________ FILED IN 1st COURT OF APPEALS IN THE FIRST COURT OF APPEALS IN HOUSTON, TEXASHOUSTON, TEXAS 6/25/2015 11:22:33 AM ________________________________________ CHRISTOPHER A. PRINE Clerk NATIONWIDE DISTRIBUTION SERVICES, INC., Appellant, v. ROBERT JONES AND POLY TRUCKING, INC., Appellees. ________________________________________ On appeal from the 133rd Judicial District Court of Harris County, Texas ________________________________________ UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLEE, POLY TRUCKING, INC. ________________________________________ Tracy J. Willi Texas Bar No. 00784633 Willi Law Firm, P.C. 9600 Escarpment Blvd., Suite 745, PMB 34 Austin, TX 78749-1983 Tel. (512) 288-3200 Fax (512) 288-3202 twilli@willi.com ATTORNEY FOR APPELLEE, POLY TRUCKING, INC. UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME Poly Trucking, Inc., Appellee, files this Unopposed Second Motion for Extension of Time to File Brief of Appellee, Poly Trucking, Inc., and would show this Court as follows. This is an interlocutory appeal of an Order denying a Special Appearance. The Order was signed on February 23, 2015. Nationwide Distributions Services, Inc. (NDS) filed its Notice of Appeal on March 6, 2015. The Brief of Appellee, Poly Trucking, Inc., is currently due on June 29, 2015. This Court has granted a second extension of time for the Brief of Appellee, Robert Jones, to be filed on July 29, 2015. Poly Trucking, Inc. requests this extension of time in order to incorporate matters contained in the supplemented record prior to filing the Brief of Appellee, Poly Trucking, Inc., and to maintain the same briefing schedule as Appellee, Robert Jones. Therefore, Poly Trucking, Inc. requests this Court to extend the deadline to July 29, 2015, to file the Brief of Appellee, Poly Trucking, Inc. 2 Respectfully submitted, /s/ Tracy J. Willi Tracy J. Willi Texas Bar No. 00784633 Willi Law Firm, P.C. 9600 Escarpment Blvd., Ste.745, PMB 34 Austin, TX 78749 Tel. (512) 288-3200 Fax (512) 288-3202 twilli@willi.com ATTORNEY FOR APPELLEE, POLY TRUCKING, INC. CERTIFICATE OF CONFERENCE I hereby certify that Counsel for Appellant, Nationwide Distribution Services, Inc., and Counsel for Appellee, Robert Jones, are not opposed to this motion. /s/ Tracy J. Willi Tracy J. Willi 3 CERTIFICATE OF FILING AND SERVICE I hereby certify that this document was filed with Clerk of Court through the Court’s electronic filing system and served on opposing counsel by the same manner or, if counsel is not registered for service through the electronic filing system, then by facsimile on June 25, 2015 as follows: Robert L Ramey Jack McKinley Ramey Chandler Quinn & Zito, P.C. 750 Bering Dr., Ste. 600 Houston, TX 77057 Tel. (713) 266-0074 Fax (713) 266-1064 Counsel for Appellant, Nationwide Distribution Services, Inc. Cory Daniel Itkin Arnold & Itkin LLP 6009 Memorial Dr. Houston, TX 77007 Tel. (713) 222-3800 Fax (713) 222-3850 Counsel for Appellee, Robert Jones Chad Flores Russell S. Post Beck Redden LLP 1221 McKinney, Suite 4500 Houston, TX 77010 Tel. (713) 951-3700 Fax (713) 951-3720 cflores@beckredden.com rpost@beckredden.com Counsel for Appellee, Robert Jones 4 Ruark D. Mershon 2000 W. Marshall Dr. Grand Prairie, TX 75051 Tel. (971) 337-7692 Fax (972) 337-8139 Co-Counsel for Appellee, Poly Trucking, Inc. /s/ Tracy J. Willi Tracy J. Willi 5