Steven E. Lau, Trustee of the Steven E. Lau Trust, Steven E. Lau, Individually, and Ken Morris v. James Reeder and Eddie Corbitt

ACCEPTED
05-14-01459-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
12/7/2015 2:48:45 PM
LISA MATZ
CLERK

IN THE COURT OF APPEALS
FIFTH DISTRICT OF TEXAS AT DALLAS

FILED IN
5th COURT OF APPEALS
CAUSE NO. 05-14-01459-CV DALLAS, TEXAS
12/7/2015 2:48:45 PM
LISA MATZ
STEVEN E. LAU, TRUSTEE OF THE STEVEN E. LAU TRUST,Clerk
STEVEN E. LAU, INDIVIDUALLY, AND KEN NORRIS.
Appellants,

v.

JAMES REEDER AND EDDIE CORBITT,
Appellees,

On Appeal from the County Court at Law No. 4 of
Dallas County, Texas
Trial Court Cause No. CC-98-00869-D

APPELLANTS’ UNOPPOSED THIRD MOTION FOR EXTENSION OF DEADLINE

TO FILE APPELLANTS’ REPLY BRIEF DUE TO HEALTH REASONS

OF APPELLANTS’ ATTORNEY

Baltasar D. Cruz
Texas Bar No. 05196150
P.O. Box 600823
Dallas, Texas 75360
telephone: (214) 369 - 9058
telecopier: (732) 875 - 0792
email: BaltasarDCruz@aol.com

ATTORNEY FOR APPELLANTS
STEVEN E. LAU, TRUSTEE OF THE STEVEN E. LAU TRUST,
STEVEN E. LAU, INDIVIDUALLY, AND KEN NORRIS

APPELLANTS’ UNOPPOSED THIRD MOTION FOR EXTENSION OF DEADLINE
TO FILE APPELLANTS’ REPLY BRIEF DUE TO HEALTH REASONS
OF APPELLANTS’ ATTORNEY Page 1
Lau.RdrRplyBrfExt3.Mtn
TO THE HONORABLE COURT OF APPEALS:

NOW COME STEVEN E. LAU, TRUSTEE OF THE STEVEN E. LAU TRUST,

STEVEN E. LAU, INDIVIDUALLY, AND KEN NORRIS (hereinafter referred to as

“Appellants”), the Appellants in the above-styled and numbered appeal, and file this, Appellants’

Unopposed Third Motion for Extension of Deadline to File Appellants’ Reply Brief Due to

Health Reasons of Appellants’ Attorney, and, in support of same, respectfully show:

I.

1.1 The current deadline for Appellants to file Appellants’ Reply Brief in the above-styled

and numbered appeal is December 9, 2015.
1.2 Appellants respectfully ask this Court to grant a thirty (30) day extension of the

December 9, 2015 deadline for Appellants to file Appellants’ Reply Brief in this matter until

January 8, 2016 because Appellants’ attorney requires additional time to prepare Appellants’

Reply Brief due to the number and complexity of the issues involved in this appeal and because

Appellants’ attorney, who is a sole practitioner, has been unable to work for several weeks

due to having severely strained his back on November 8, 2015 (for which he has sought

treatment from John H. Peloza, M.D. at the Texas Back Institute) and also, in the past week,

suffering from severe fatigue, nausea, abdominal discomfort, sneezing, a runny nose, and a

persistent cough due to an apparent virus and/or a cold.

1.3 This is the third extension that has been requested of the deadline for filing

Appellants’ Reply Brief in this appeal.

1.4 Appellants’ attorney has conferred with Appellees’ counsel regarding this motion

and confirmed that Appellees’ counsel do not oppose this motion.
1.5 This extension is not sought for purposes of delay but so that justice may be served

because Appellants’ counsel requires additional time to prepare Appellants’ Reply Brief in this

matter for the reasons stated above.

WHEREFORE, PREMISES CONSIDERED, Appellants respectfully request that they be

APPELLANTS’ UNOPPOSED THIRD MOTION FOR EXTENSION OF DEADLINE
TO FILE APPELLANTS’ REPLY BRIEF DUE TO HEALTH REASONS
OF APPELLANTS’ ATTORNEY Page 2
Lau.RdrRplyBrfExt3.Mtn
granted a thirty (30) day extension until January 8, 2016 of the December 9, 2015 deadline for

Appellants to file Appellants’ Reply Brief in the above-referenced matter and that Appellants be

granted such other and further relief to which they may be justly entitled.

Respectfully submitted,

/s/ Baltasar D. Cruz
Baltasar D. Cruz
Texas Bar No. 05196150
P.O. Box 600823
Dallas, Texas 75360
Telephone: (214) 369-9058
Telecopier: (732) 875-0792
e-mail: BaltasarDCruz@aol.com
COUNSEL FOR APPELLANTS
STEVEN E. LAU, TRUSTEE OF THE STEVEN
E. LAU TRUST, STEVEN E. LAU,
INDIVIDUALLY, and KEN NORRIS

CERTIFICATE OF CONFERENCE

I certify that I have conferred with opposing counsel regarding the merits of this motion
and have confirmed that they are unopposed to this motion.

/s/ Baltasar D. Cruz
Baltasar D. Cruz

CERTIFICATE OF SERVICE

I certify that on this, the 7th day of December, 2015, a complete and accurate copy of this
document was electronically served upon the following attorneys, whom jointly represent
Appellees Eddie Corbitt and James Reeder, by means of transmission to their respective
electronic filing service providers, in compliance with rule 9.5(b)(1) of the Texas Rules of
Appellate Procedure:

Mark L. Taylor
Peyton Healey
POWERS TAYLOR LLP
8150 North Central Expressway, Suite 1575
Dallas, TX 75206

Mr. Zachary M. Groover
Groover Hamilton, LLP
555 Republic Dr., Suite 200
Plano, TX 75074
/s/ Baltasar D. Cruz
Baltasar D. Cruz

APPELLANTS’ UNOPPOSED THIRD MOTION FOR EXTENSION OF DEADLINE
TO FILE APPELLANTS’ REPLY BRIEF DUE TO HEALTH REASONS
OF APPELLANTS’ ATTORNEY Page 3
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