Tan Duc USA v. Jimmy Tran

ACCEPTED 01-14-00539-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 7/13/2015 12:00:00 AM CHRISTOPHER PRINE CLERK NO. 01-14-00539-CV FILED IN - 1st COURT OF--APPEALS - ---- HOUSTON, - --- TEXAS - ----ID K ------ IN THE COURT OF APPEALS 7/12/2015 - - 5:39:51 - -- PM ---- VO ------ FOR THE FIRST SUPREME JUDICIAL DISTRICTCHRISTOPHER OF TEXAS -- A. PRINE ---- HOUSTON, TEXAS ----Clerk HOANG-YEN THI DANG, and FILED IN TAN DUC CONSTRUCTION LIMITED COMPANY, 1st COURT OF APPEALS HOUSTON, TEXAS Appellants 7/13/2015 11:02:00 AM v. CHRISTOPHER A. PRINE Clerk JIMMY TRAN, Appellee and Conditional Cross-Appellant TRAN’S MOTION TO ADJUST BRIEFING DEADLINES TO THE HONORABLE FIRST COURT OF APPEALS: Appellant Dang has not filed her brief. By an agreed motion, filed by Tran and Dang on February 27 and granted March 10, Appellee/Conditional Cross- Appellant Tran’s Brief was to be filed Thirty-Five (35) days after Appellant Dang filed her brief, and thus specifically on July 13, because Appellant’s Dang’s deadline was to be re-set to June 8. (Later Dang requested a week’s extension, which was granted, to June 15.) Tran moves that Tran’s deadline to brief in response to Dang and to present Tran’s conditional cross-appellant’s brief be adjusted to the 35th day after (and if) Dang files, if with leave, her Appellant’s brief. Apart from his joining the February 27 joint motion, this is Tran’s first request to adjust his briefing deadlines as to Dang. Tran requests a separate briefing adjustment as to Appellant Tan Duc. Appellant Tan Duc did not join in the February joint motion to adjust briefing deadlines, yet seemingly presumes it was included in the Court’s March 10 order, since on July 15 Tan Duc filed its motion seeking leave to extend its briefing deadline “from June 8" to June 18. This Court on June 16 granted that motion in part, extending Tan Duc’s deadline to June 15. Tran moves that his deadline to brief in response to Tan Duc be extended to July 27, 2015. Tran has not previously asked for an extension of his briefing deadlines as to Tan Duc. Tran believes these motions are unopposed. Dang’s new appellate counsel stated in June he would not oppose Tran’s request to adjust briefing deadlines in light of Dang’s requests then being made. Tan Duc advised this Court it presumed Tran would not oppose Tan Duc’s June 16 request, and Tran presumes it may expect the same from Tan Duc, as Tan Duc presumed from Tran. 2 Concluding, Tran moves: 1. That Tran’s brief as Appellee and Cross-Appellant be due 35 days after Dang files her brief with leave to do so, if Dang files her brief; and, 2. that Tran’s briefing as Appellee as to Tan Duc be due July 27, 2015. Respectfully submitted, /S/ Matt Muller Matthew S. Muller Texas Bar No. 14648450 1445 North Loop West, Suite 760 Houston, Texas 77008 Tel. (713)227-1888 Fax. (713)227-1881 Attorney for Tran Certificate of Service I will cause the e-filing system to serve a true copy of this instrument on all counsel this 12th day of July, 2015. /S/ Matthew Muller C:\Users\Home\Dropbox\TRAN Appellate\motion to adjust briefing deadlines.wpd 3