Akhil Patel v. Nadia Hussain

ACCEPTED
14-14-00459-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
4/14/2015 5:19:25 PM
CHRISTOPHER PRINE
CLERK

No. 14-14-00459-CV

A.P., § FILED IN
14th COURT OF APPEALS
§ HOUSTON, TEXAS
Appellant § 4/14/2015 5:19:25 PM
§ Court of Appeals of Texas
CHRISTOPHER A. PRINE
Clerk
v. §
§ Fourteenth District
N.H., §
§
Appellee §

Appellee’s Unopposed Motion for Extension of Time
to File Appellee’s Brief

Appellee N.H. files this Unopposed Motion for Extension of Time to file

Appellee’s Brief and would respectfully show this Court the following:

1. Appellee’s Brief is due April 15, 2015.

2. Appellee respectfully requests an 8-day extension of her deadline. If

permitted, his brief would be due on April 23, 2015.

3. Appellee seeks this extension because, during the previous thirty days

and through tomorrow, her counsel has been obligated with the following

additional deadlines:

— March 23, 2015: Response to Motion to Dismiss in Wesson v. City of
Dallas, which is pending in the United States District Court for the
Northern District of Texas as Civil Action No. 3:14-CV-4325;
— March 24, 2015: Response to three motions for summary judgment in
Melendez v. Rumsey Site Construction, LLC, which is pending in the
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 62nd Judicial District Court of Hopkins County, Texas as Cause No.
CV-41232;
— March 30, 2015: Response to motion for summary judgment in Blair v.
City of Dallas, which is pending in the United States District Court
for the Northern District of Texas as Civil Action No. 3:14-CV-1515;
— March 31, 2015: Hearing on three motions for summary judgment in
Melendez v. Rumsey Site Construction, LLC, which is pending in the
62nd Judicial District Court of Hopkins County, Texas as Cause No.
CV-41232;
— April 6, 2015: Response to Motion to Dismiss in Harper v. City of
Dallas, which is pending in the United States District Court for the
Northern District of Texas as Civil Action No. 3:14-CV-2647; and
— April 7, 2015: Response to Motion to Dismiss in Tolan v. City of
Bellaire, which is pending in the United States District Court for the
Southern District of Texas as Civil Action No. 4:09-CV-1324;
— April 9, 2015: Full-day mediation in Melendez v. Rumsey Site
Construction, LLC, which is pending in the 62nd Judicial District
Court of Hopkins County, Texas as Cause No. CV-41232;
— April 13, 2015: Appellant’s Brief due in Gonzalez v. Northfork
Investments, Ltd., which is pending in the Fifth Court of Appeals as
Case No. 05-14-01418-CV;
— April 15, 2015: CLE presentation in Lubbock, Texas; and
— April 16, 2015: CLE presentation in San Antonio, Texas

4. Appellee has requested and received one previous thirty-day extension

of time to file her brief in this case.

5. This motion is not made for purposes of delay, but so that justice may

be done.

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 Respectfully submitted,

s/ Matthew J. Kita
Matthew J. Kita
Texas Bar No. 24050883
1400 Congress Street
Houston, Texas 77002
(713) 222-2000 (telephone)
(713) 222-2329 (facsimile)
matt@mattkita.com
Counsel for Appellee

Certificate of Conference

On April 14, 2015, I conferred with Appellant’s counsel regarding the merits
of this motion, who represented that he is unopposed to the relief requested.

/s/ Matthew J. Kita
Matthew J. Kita

Certificate of Service

The undersigned certifies that a copy of this filing was served on the
following counsel via e-filing in accordance with Texas Rule of Appellate Procedure
9.5 and this Court’s Local Rules on April 14, 2015:

Counsel for Appellant:

Tej Paranjpe
Paranjpe & Mahadass LLP
3701 Kirby Drive, Suite 530
Houston, TX 77098

s/ Matthew J. Kita
Matthew J. Kita

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