Peter D. Tran, Nam Van Nguyen, the Kim Hoang and Tuyen Ngoc Bui, on Behalf of the Vietnamese Community of Houston & Vicinity, Inc. a Non-Profit Corporation v. Aloysius Duy-Hung Hoang, Teresa Ngoc-Bich Hoang, Cavatina Truong, Skybird Nguyen and Hoc Nhu Phan
ACCEPTED
01-14-00973-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/21/2015 4:11:01 PM
CHRISTOPHER PRINE
CLERK
NO. 01-14-00973-CV
PETER D. TRAN, NAM VAN § IN THE FIRST FILED IN
1st COURT OF APPEALS
NGUYEN, THE KIM HOANG, § HOUSTON, TEXAS
AND TUYEN NGOC BUI § 9/21/2015 4:11:01 PM
ON BEHALF OF THE § CHRISTOPHER A. PRINE
VIETNAMESE COMMUNITY OF § Clerk
HOUSTON & VICINITY, INC., §
Appellants, §
§
VS. § COURT OF APPEALS
§
ALOYSIUS DUY-HUNG HOANG, §
TERESA NGOC-BICH HOANG, §
CAVATINA TRUONG, SKYBIRD §
NGUYEN AND HOC NHU PHAN, §
Appellees. § HOUSTON, TEXAS
APPELLANTS' MOTION TO EXTEND TIME TO FILE REPLY BRIEF
Appellants ask the Court to extend the time to file their Reply Brief
A. Introduction
1. Appellants are Peter D. Tran, Nam Van Nguyen, The Kim Hoang, and Tuyen
Ngoc Bui on Behalf of the Vietnamese Community of Houston & Vicinity, Inc.
2. This Motion to Extend Time to File Reply Brief is brought pursuant to Rule
10.5(b) of the Texas Rules of Appellate Procedure.
B. Argument & Authorities
3. The Court has the authority under Texas Rule of Appellate Procedure 10.5(b)
to extend the time to file the reply brief.
4. Appellants request an additional 4 days to file their reply brief, extending the
time until September 25, 2015.
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5. Two previous short extensions have been requested and granted to extend the
time to file Appellants' Reply Brief.
6. Appellants need additional time to file their Reply Brief because Appellants'
counsel has been became involved in an emergency filing requiring an emergency
temporary orders hearing in the 505th Judicial District Court set for September 22,
2015 at 9:30 a.m. Counsel has had to prepare for the hearing which has taken time
away from completion of the Reply Brief. Appellants' counsel requires additional
time to complete the drafting of the Reply Brief.
C. Conclusion
7. Appellants require additional time to complete their Reply Brief
D. Prayer
8. For these reasons, Appellants ask the Court to grant an extension of time to
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file their Reply Brief until September 25, 2015.
Respectfully submitted,
ALLAN A. CEASE & ASSOCIATES, P.C.
e N
BY: Allan A. Cease
Texas Bar No. 04040550
Email: allancease@comcast.net
56 Sugar Creek Center Blvd, Suite 300
Sugar Land, Texas 77478
Tel. 281-980-0909
Fax 281-980-1069
Attorney for Appellants, Peter D. Tran, Nam Van
Nguyen, The Kim Hoang, and Tuyen Ngoc Bui
on Behalf of the Vietnamese Community of
Houston & Vicinity, Inc.
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VERIFICATION
STATE OF TEXAS
FORT BEND COUNTY §
Before me, the undersigned notary, on this day personally appeared Allan A.
Cease, the affiant, a person whose identity is known to me. After I administered an
oath to affiant, affiant testified:
"My name is Allan A. Cease. I am capable of making this verification. I have
read the Appellants' Motion to Extend Time to File Reply Brief The facts stated in
it are within my personal knowledge and are true and correct."
Allan A. Cease
SWORN TO AND SUBSCRIBED BEFORE ME by Allan A. Cease on
September 21, 2015.
••,,,e ANNIE NGUYEN
Notary Puatic, State of Texos
My CarornistOon Expires of Texas
'4%fai ..... Apia 17, 2019
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CERTIFICATE OF CONFERENCE
I certify that I have conferred with Brent C. Perry and he is unopposed to this
motion.
af/
Allan A. Cease
CERTIFICATE OF SERVICE
I certify that a copy of Appellants' Motion to Extend Time to File Brief was
served on Appellees, Aloysius Duy-Hung Hoang, Teresa Ngoc-Bich Hoang, Cavatina
Truong, Skybird Nguyen and Hoc Nhu Phan, through counsel of record, Brent C.
Perry, at 800 Commerce Street, Suite 102, Houston, Texas 77002, by email to
brentperry@brentperrylaw.corn, on September 21, 2015.
ieeN
llan A. Cease
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