WC 1217-1221 Haven Lane, LP v. Mid-Century Insurance Co. and Parke Moyer

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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 2 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 3 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 4