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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