ACCEPTED
01-15-00197-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/17/2015 12:00:00 AM
CHRISTOPHER PRINE
CLERK
No.Ol-15-00197-CV
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURT OF ApPEALS 8/17/2015 8:48:00 AM
FOR THE FmST DISTRICT OF TEXAS CHRISTOPHER A. PRINE
AT HOUSTON Clerk
LETICIA LOYA,
Appellant,
v.
IAN TAYLOR, JACOBUS STERKEN, STICHTING TINSEL GROUP, VITOL
HOLDING IIS.A., AND TINSEL GROUP, S.A.,
Appellees.
Appeal from the 190th Judicial District Court, Harris County, Texas
Trial Court Cause No. 2012-33464
UNOPPOSED SECOND MOTION TO EXTEND
TIME FOR FILING APPELLANT'S REPLY BRIEF
TO THE HONORABLE FIRST COURT OF APPEALS:
LETICIA LoyA, Appellant, moves this Court to grant an extension of
time to file Appellant's Reply Brief, and respectfully states:
1. Appellant's Briefis due to be filed with this court on or about August 14,
2015.
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2. Appellant seeks a one (1) day extension of time to file Appellant's Brief,
which would make Appellant's Brief due on or before August 17, 2015.
3. This extension of time is necessary because lead counsel for Appellant's
legal assistant inadvertently overlooked the deadline while assisting another
counsel for trial in an unrelated matter. Also, lead counsel for Appellant
was/is participating in several oral arguments, appeals and/or trials with
deadlines prior to the August 14thdeadline:
• Universal Gold Coin v. FedEx et al, Western District of Tennessee
(pre-trial motions)
• Altamirano v. KONE, 136th Judicial District of Texas (pretrial
motions)
• Tomsic v. Real Flame Co., Inc., Eastern District of Texas (responses
to motions to dismiss)
• Bortz v. The Tuthill Corporation, d/b/a Blue Mountain Ski Area,
Carbon County, Pennsylvania (pre-trial motions)
As a result, time constraints will make it difficult to adequately
prepare the brief in this appeal. This request is not filed for the purpose of
delay, but rather to afford counsel adequate time to prepare the reply brief.
Therefore, additional time is needed to adequately prepare the arguments in
this case.
4. Counsel for Appellant has conferred with counsel for Appellees Ian
Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A.,
Tinsel Group, S.A., and Miguel Loya, and Appellees do not oppose this
motion to extend time.
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5. This is the second extension of time Appellant has sought for the filing of
the Appellant's Reply Brief.
For these reasons, LETICIALOYA, Appellant, requests that this Court
render an order extending the time for filing Appellant's Brief to and
including August 17,2015. Appellant also requests any other relief to which
she may be entitled.
Respectfully submitted,
PROVOST* UMPHREY LAW FIRM,
L.L.P.
490 Park Street
P. O. Box 4905
Beaumont, Texas 77704
(409) 835-6000
(409) 813-8682 (FAX)
By: / s / Jennifer Job
Jennifer Job
Texas State Bar No. 24050682
James Payne
Texas State Bar No. 00788171
ATTORNEYS FOR APPELLANT
CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with counsel for Appellees Miguel
Loya, Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II
S.A., and Tinsel Group, S.A. concerning this motion, and Appellees do not
oppose the relief requested in this motion.
/ s / Jennifer Job
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CERTIFICATE OF SERVICE
I hereby certify that a copy of this motion to amend notice of appeal
has been sent to all known counsel of record via EFILE and/or certified
mail, return receipt requested on August 15, 2015.
/ s / Jennifer Job
Jennifer Job
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Leticia B. Loya v. Vitol, Inc., Michael Metz, and Antonio Maarraoui
Combined Opinion