ACCEPTED
01-15-00260-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/17/2015 1:34:57 PM
CHRISTOPHER PRINE
NO. 01-15-00260-CV CLERK
IN THE COURT OF APPEALS
FOR THE 1ST JUDICIAL DISTRICT OF TEXAS
AT HOUSTON FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
9/17/2015 1:34:57 PM
CHRISTOPHER A. PRINE
JOAN DEYOUNG, STEPHEN DEYOUNG, M.D, AND DAVID DEYOUNG,
Clerk
Appellants,
V.
Judy Page Maynard, William L. Maynard, Maynard Properties, L.P.,
Appellees.
FROM THE 270TH JUDICIAL DISTRICT COURT
OF HARRIS COUNTY, TEXAS
APPELLEES’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
Gregory N. Jones
SBN 10889450
Law Office of Gregory N. Jones
2323 S. Shepherd, 14th Fl.
Houston, Texas 77019
(713) 979-4691
(713) 979-4440 – fax
Counsel for Appellees
Appellees’ Unopposed Motion for Extension of Time
Appellees’ counsel has been involved in several litigation
matters out of the county and State litigation matters, Appellees
respectfully requests a thirty (30) day extension of the deadline to file their
response brief in this appeal.
BACKGROUND FACTS
1. On March 19, 2015, the DeYoungs filed their notice of appeal.
The clerkʼs record was filed on June 16, 2015, the Appellants’ brief was filed
on August 17, 2015, which means that Appellees’ brief is due September
17, 2105.
2. Appellees’ counsel is handling several complex cases that
have required an inordinate amount of time and attention over the past
several months.
3. These matters, and the resulting time constraints, have
prevented Appellees’ counsel from devoting the necessary time and
attention to their response brief.
4. This is the Appellees’ counsel first request for an extension
of time to file their response brief, which is unopposed.
Appellees’ Unopposed Motion for Extension of Time 2
PRAYER / RELIEF REQUESTED
For the foregoing reasons, appellants Joan DeYoung, Stephen
DeYoung, M.D., and David DeYoung request a 30-day extension of the
deadline to file his brief, which would make the DeYoungsʼ brief due on
August 17, 2015 (August 15th is a Saturday).
Respectfully submitted,
Law Office OF GREGORY N. JONES
/s/ Gregory N. Jones
Gregory N. Jones
2323 S. Shepherd, 14th Fl.
Houston, Texas 77019
(713) 979-4691
(713) 979-4440 – fax
gjones@gnjlaw.net
Counsel for Appellees
CERTIFICATE OF CONFERENCE
I certify to the Court that I have conferred with appelleesʼ counsel who
indicated that appellees are unopposed to the relief sought by this motion.
/s/ Gregory N. Jones
Gregory N. Jones
Appellees’ Unopposed Motion for Extension of Time 3
CERTIFICATE OF COMPLIANCE
Pursuant to TEX. R. APP. P. 9.4(i), I certify to the Court that the
foregoing document contains 371 words. In calculating the word count, I
relied on the “Word Count” function of the computer program used to
generate this document.
/s/ Gregory N. Jones
Gregory N. Jones
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing document has been electronically
served on all counsel of record on September 17, 2015:
Daniel W. Jackson, SBN 007968 William L. Maynard
Scott K. Vastine, SBN 24056469 1300 Post Oak Blvd., Suite 2500
3900 Essex Lane, Suite 1116 Houston, Texas 77056
Houston, Texas 77027 (713) 623-0887
(713) 522-4435 (713) 960-1527 – fax
(713) 527- 8850 – fax
daniel@jacksonlaw-tx.com
scott@jacksonlaw-tx.com
/s/ Gregory N. Jones
Gregory N. Jones
Appellees’ Unopposed Motion for Extension of Time 4
Joan DeYoung, Stephen DeYoung, M.D., and David DeYoung v. William L. Maynard, Individually and as of the Estate of Judy Page Maynard, and Maynard Properties, L.P.
Combined Opinion