ACCEPTED
01-15-00435-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/30/2015 4:19:01 PM
CHRISTOPHER PRINE
CLERK
01-15-155-CV
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE FIRST COURT OF APPEALS FOR TEXAS7/30/2015 4:19:01 PM
CHRISTOPHER A. PRINE
Clerk
IRVING DROBNY, AS REPRESENTATIVE OF NAIU AND NAIC,
Appellants,
v.
ANICO,
Appellee.
ON APPEAL FROM
405TH DISTRICT COURT
GALVESTON COUNTY, TEXAS
CAUSE NO. 12-CV-1131
UN-OPPOSED MOTION TO EXTEND TIME TO
FILE APPELLANT’S BRIEF
TO THE JUSTICES OF THE FIRST COURT OF APPEALS:
Appellants ask this court to grant this motion for extension of time to file the
Appellant’s Brief for three weeks.
1. The Appellant’s Brief was due July 30, 2015
2. Appellant’s counsel has been responding to a Petition for Rehearing Enc Banc, in
cause number 14-40114, McCaig v. Wells Fargo, in the Fifth Circuit, including
response, and sur-reply.
3. In part because of the press of that business, as well as a jury trial that was held
July 6 – 8, Counsel did not realize that she had not obtained a copy of the record
from the Clerk. It is normal in this practice to work from original (highlighted and
marked up) copies of documents, and add pagination to the record as one of the
last steps. The record was checked out today, July 30, 2015.
4. In conferencing with opposing counsel, she is going on vacation and would prefer
that the brief not be filed during her absence, so she will have a full period to
respond. She graciously does not oppose this request.
PRAYER
For all these reasons, appellant asks this Court to grant an extension of time to file
the Appellant’s Brief to August 20, 2015.
Respectfully submitted,
_/s/ Savannah Robinson ________________
Savannah Robinson
Texas Bar No. 17108150
1822 Main
Danbury, TX 7534
Telephone: 979-922-8825
Savannahrobinson@aol.com
Attorneys for Appellant
CERTIFICATE OF CONFERENCE
I emailed and forwarded correspondence by fax to Roni Mihaly, the attorney for
appellee, who does not oppose this extension.
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_/s/ Savannah Robinson ________________
Savannah Robinson
CERTIFICATE OF SERVICE
I certify that a true and correct copy of this Opposed Motion to Extend Time to
File Appellant’s Brief was served on all counsel of record by first class mail on July 30,
2015.
_/s/ Savannah Robinson_________________
Savannah Robinson
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