Frank M. Seliger v. Ethiopian Evangelical Church

ACCEPTED 03-14-00621-CV 5028711 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/24/2015 3:51:47 PM JEFFREY D. KYLE CLERK NO. 03-14-00621CV FILED IN IN THE COURT OF APPEALS 3rd COURT OF APPEALS AUSTIN, TEXAS THE THIRD DISTRICT OF TEXAS 4/24/2015 3:51:47 PM JEFFREY D. KYLE AUSTIN, TEXAS Clerk FRANK SELIGER, Appellant V. THE ETHIOPIAN EVANGELICAL CHURCH, Appellee. Appeal from the County Court at Law Number One Travis County, Texas Trial Court Case No. C-1-CV-14-005819 Hon. David Phillips, presiding APPELLEE’S SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF TO THE HONORABLE COURT OF APPEALS: COMES NOW APPELLEE, ETHIOPIAN EVANGELICAL CHURCH, who files this Motion for Extension of Time to File its Appeal Brief and respectfully shows the following: 1. Appellee’s deadline to file its Appeal Brief is April 24, 2015. Appellee’s Second Motion for Extension of Time to File Appellee’s Brief Page 1 2. Part of the practice of Appellee’s counsel involves a foreclosure prevention program and the prevention of evictions. Counsel for Appellee is presently dealing with an emergency situation concerning clients who are facing immediate eviction from their homes and, next week, counsel for Appellee will be working to prevent foreclosures for clients who are scheduled to have their homes sold due to foreclosure proceedings on May 5, 2015. For these reasons, counsel for Appellee is in need of additional time to complete and file the Appellee’s Appeal Brief. 3. Appellee requests a two-week extension of time on which to file its Appeal Brief to May 8, 2015. WHEREFORE, PREMISES CONSIDERED, Appellee prays this Court grant its Motion for Extension of Time to File its Appeal Brief and extend its deadline to file same to May 8, 2015. Respectfully submitted, By: /s/ James Minerve ____________________________ James Minerve State Bar No. 24008692 115 Saddle Blanket Trail Buda, Texas 78610 (210) 336-5867 (888) 230-6397 (Fax) jgminerve@aol.com jgm@minervelaw.com Attorney for Appellee Appellee’s Second Motion for Extension of Time to File Appellee’s Brief Page 2 CERTIFICATE OF CONFERENCE On April 24, 2015, the undersigned counsel for Appellee conferred with pro se Appellant, Frank Seliger, concerning the foregoing Motion and Mr. Seliger stated that he is not opposed to this Motion. See Exhibit A. /s/ James Minerve ______________________________ James Minerve CERTIFICATE OF SERVICE I hereby certify that on this 24th day of April, 2015 a true and correct copy of the above and foregoing document was sent via Efile.txcourts.gov electronic filing notification system and via e-mail to the parties of record listed below: Appellant Pro Se: Frank Seliger 2108 East Yager Lane Austin, Texas 78754 E-mail: digitalfranks@att.net /s/ James Minerve ______________________________ James Minerve Appellee’s Second Motion for Extension of Time to File Appellee’s Brief Page 3