Phap v. Nguyen, Andy Ngo and Dung T. Vu v. Manh Hoang and Dung Le

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ACCEPTED 01-15-00352-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 8/27/2015 1:29:39 PM CHRISTOPHER PRINE CLERK CAUSE NO. 01-15-00352-CV FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS HOUSTON, TEXAS HOUSTON, TEXAS 8/27/2015 1:29:39 PM CHRISTOPHER A. PRINE Clerk __________________________________________________________________ PHAP V. NGUYEN, ANDY NGO, and DUNG T. VU, Defendants - Appellants VS. MANH HOANG and DUNG LE, Plaintiffs – Appellees On Appeal from the 55th Judicial District Court Harris County Cause No. 2011-72719 _________________________________________________________ FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF _____________________________________________________ BUI & NHAN, P.L.L.C. Scott K. Bui State Bar No.00789185 Email: sbui@buinhanlaw.com Charlie T. Nhan State Bar No. 24025561 Email: cnhan@buinhanlaw.com 3921 Ocee Houston, Texas 77063 Tel: 713-783-2466 Fax: 713-783-0787 ATTORNEYS FOR APPELLEES TO THE HONORABLE FIRST COURT OF APPEALS: Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellees, MANH HOANG and DUNG LE, file this Unopposed First Motion to Extend Time to File Appellees’ Brief. Appellees’ opening brief is currently due on August 28, 2015. Counsel for Appellees request a 30-day extension of time to file its brief, making the brief due on September 28, 2015. This is the first request for extension of time to file the opening brief. Counsel for Appellees rely on the following reason, in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the requested extension: Counsel for Appellees has encountered a computer related issue regarding the data on his drive that were corrupted. Counsels for Appellees seek this extension of time to be able to prepare a cogent and succinct brief to aid this Court in its analysis of the issues presented. This request is not sought for delay but so that justice may be done. The undersigned has conferred with opposing counsel, and he has indicated that his client does not oppose this motion. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2. PRAYER FOR RELIEF For the reasons set forth above, Appellees request that this Court grant this Unopposed First Motion to Extend Time to File Appellees’ Brief and extend the Deadline for Filing the Appellees’ Brief up to and including September 28, 2015. Appellees pray for all other relief to which it may be entitled. Respectfully submitted, Bui & Nhan, PLLC. 2 By: /s/ Scott K. Bui BUI & NHAN, P.L.L.C. Scott K. Bui State Bar No.00789185 Email: sbui@buinhanlaw.com Charlie T. Nhan State Bar No. 24025561 Email: cnhan@buinhanlaw.com 3921 Ocee Houston, Texas 77063 Tel: 713-783-2466 Fax: 713-783-0787 ATTORNEYS FOR APPELLEES CERTIFICATE OF CONFERENCE I certify that I conferred with counsel for Appellants regarding this motion and that Appellants are opposed to this motion. /s/ Scott K. Bui Scott Khoa Bui CERTIFICATE OF SERVICE I hereby certify that, on August 28, 2015, a copy of the foregoing was delivered in a manner prescribed by the Texas Rules of Appellate Procedure to: Tom Rorie Via Facsimile #936-559-0099 /s/ Scott K. Bui Scott Khoa Bui -3-