ACCEPTED
07-15-00026-CV
SEVENTH COURT OF APPEALS
AMARILLO, TEXAS
11/18/2015 9:59:04 AM
Vivian Long, Clerk
CASE NO. 07-15-00026-CV
IN THE COURT OF APPEALS FOR THE FILED IN
SEVENTH DISTRICT OF TEXAS7th COURT OF APPEALS
AMARILLO, TEXAS
11/18/2015 9:59:04 AM
__________________________________________________________________
VIVIAN LONG
CLERK
WC 1217-1221 HAVEN LANE, LP,
Plaintiff/Appellant,
v.
MID-CENTURY INSURANCE CO. AND PARK MOYER,
Defendants/Appellees.
__________________________________________________________________
ON APPEAL FROM CAUSE NO. 13-0730-C368
368TH DISTRICT COURT, WILLIAMSON COUNTY, TEXAS
_________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION TO FILE
APPELLANT’S REPLY BRIEF
_________________________________________________________________
TO THE HONORABLE COURT OF APPEALS:
Counsel for Appellant, WC 1217-1221 Haven Lane, L.P., hereby files the
present Unopposed Motion for an Extension of Time to File Appellant’s Reply
Brief. Specifically, due to the upcoming holiday and also due to a recent
development where counsel has a trial setting in the K-192nd Judicial District
Court of Dallas County, Texas, in a matter styled Brockwood Properties LP v. State
Farm Lloyds, Cause No. DC-13-09273, Appellant is humbly seeking a thirty (30)
day extension for the filing of its Reply Brief, which presently has a deadline of
November 20, 2015.
Appellee’s counsel has been informed as of the filing of the unopposed
motion for extension, and has no opposition to the request or the length of the
extension sought. Accordingly, Appellant respectfully requests this Honorable
Court grant it’s Motion for Extension of Time to File its Reply Brief and permit the
same to be filed on or before December 20, 2015. Appellant further request this
Honorable Court grant all other relief as would be appropriate, and as justice
would require under the present circumstances.
Respectfully submitted,
/s/ Scott G. Hunziker
Scott G. Hunziker
Attorney-in-Charge
Texas Bar No. 24032446
Federal I.D. No. 38752
scott@vosslawfirm.com
OF COUNSEL:
The Voss Law Firm, P.C.
26619 Interstate 45
The Woodlands, Texas 77380
Telephone: (713) 861-0015
Facsimile: (713) 861-0021
ATTORNEYS FOR APPELLANT
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CERTIFICATE OF CONFERENCE
As required by the Texas Rules of Appellate Procedure 10.1(a)(5), I certify that I
have conferred on November 17, 2015 with opposing counsel about the merits of
this motion with the following results:
MARTIN, DISIERE, JEFFERSON & WISDOM
Christopher Martin
Kevin Cain
Niels Esperson Building
808 Travis, 20th Floor
Houston, TX 77002
□ opposes motion
X does not oppose motion
□ agrees with motion
□ would not say whether motion is opposed
/s/ Scott G. Hunziker
Scott G. Hunziker
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CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copies of the
foregoing Motion for Extension was served via electronically filing on this 18th
day of November, 2015 upon
MARTIN, DISIERE, JEFFERSON & WISDOM
Christopher Martin
Kevin Cain
Niels Esperson Building
808 Travis, 20th Floor
Houston, TX 77002
/s/ Scott G. Hunziker
Scott G. Hunziker
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