Mid Pac Portfolio, LLC v. Paula Welch, Clyde Alan Ashworth and Wells Fargo Bank, Minnesota, NA Formerly Known as Norwest Bank, Minnesota, NA, as Trustee for Salomon Brothers Mortgage Securities VII, Inc. Floating Rate Mortgage Pass Through Certificates Series 1999-LBI

ACCEPTED
01-15-00404-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/19/2015 11:07:21 AM
CHRISTOPHER PRINE
CLERK

No. 01-15-00404-CV

In the First Court of Appeals FILED IN
at Houston, Texas 1st COURT OF APPEALS
HOUSTON, TEXAS
8/19/2015 11:07:21 AM
MID PAC PORTFOLIO LLC
CHRISTOPHER A. PRINE
Clerk
V.

PAULA WELCH AND CLYDE ASHWORTH

On Appeal from the 405th Judicial
District Court of Galveston County, Texas

APPELLEES’ FIRST REQUEST FOR EXTENSION
OF TIME TO FILE BRIEF
(Unopposed)

TO THE HONORABLE FIRST COURT OF APPEALS:

NOW COME Paula Welch and Clyde Ashworth, Appellees, and file this

their first request for extension of time in which to file their Brief herein.

This is a first request and is unopposed.

Appellant’s Brief was filed on July 21 2015. Appellees’ Brief is due on

August 20, 2012.

Good cause exists for extension of time. Since the filing of Appellant’s

Brief on July 21, this counsel has been heavily engaged in other matters including:

--On July 27, 2015, this counsel filed a comprehensive objection to referral

to mediation in No. 01-15-0583-CV, The Hon. Mark A. Henry v. The Hon. Lonnie
Cox, in the First Court of Appeals. The Referral to Mediation was subsequently

withdraw.

--On August 6 and 7, 2015, the undersigned counsel filed a Petition for

Review and Amended Petition for Review (to conform to TRAP 9 requirements)

with the Texas Supreme Court in No. 15-0423, Joe Murphy et al v. The City of

Galveston, seeking review of No. 14-14-00222-CV.

--The undersigned counsel is presently under a short deadline to file a brief

in No. 14-14-01020-CV, Mariano Diaz v. Kevin Johnson et al. The Brief in that

case was due on July 29, 2015 and an overdue notice was sent by the Court of

Appeals on August 7, 2015. This counsel is attempting to file the Brief on or

shortly after the 15th Day following the August 7 notice but will probably have to

file an extension request in that case as well.

Prayer

Accordingly, Appellees through their counsel request an extension of thirty

days to and including Monday, September 21, 2015 in which to file their Brief.

Respectfully submitted,
/s/ Mark W. Stevens
Mark W. Stevens
TBN 19184300
PO Box 8118
Galveston, TX 77553
409.765.6306
Fax 409.765.6469
Email: markwandstev@sbcglobal.net
 Counsel for Appellees
Paula Welch and Clyde Ashworth

Certificate of Conference
This counsel conferred with Appellant’s Counsel, Mr. Mike Burns, on
August 19, 2015, and Mr. Burns advises that he does not oppose this request for
extension.

/s/ Mark W. Stevens
Mark W. Stevens

Certificate of Compliance
The Foregoing instrument contains 273 words in Times New Roman 14
point font double spaced.

/s/ Mark W. Stevens
Mark W. Stevens

Certificate of Service
A true and correct copy of the foregoing instrument was served via efiling
on Mr. Mike Burns at burnslaw@outlook.com on August 19, 2015.

/s/ Mark W. Stevens
Mark W. Stevens