State Farm Lloyds v. Candelario Fuentes and Maria Fuentes

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ACCEPTED 14-14-00824-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 4:51:57 PM CHRISTOPHER PRINE CLERK NO. 14-14-00824-CV FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS 7/7/2015 4:51:57 PM HOUSTON, TEXAS CHRISTOPHER A. PRINE Clerk STATE FARM LLOYDS Appellant v. CANDELARIO FUENTES AND MARIA FUENTES Appellees SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S REPLY BRIEF TO THE HONORABLE COURT OF APPEALS: Appellant, State Farm Lloyds, asks for additional time to file its reply brief pursuant to TEX. R. APP. P. 10.5(b). State Farm respectfully shows as follows: 1. Appellant’s brief was filed on March 25, 2015. 2. On April 17, 2015, Appellees filed an unopposed motion for extension of time to file their brief, which the Court granted on the same day. 3. On May 22, 2015, Appellees filed an unopposed motion for extension of time to file their brief, which the Court granted on the same day. 4. Appellees’ brief was filed on June 8, 2015. 1 5. On June 16, 2015, Appellant filed an unopposed motion for extension of time to file its brief, which the Court granted on the same day. 6. Appellant’s reply brief is due to be filed on July 13, 2015. 7. Appellant respectfully requests a 10-day extension of time to file its reply brief. With the extension, its reply brief will be due July 23, 2015. 8. This is the appellant’s second request for an extension of time for filing its brief. 9. The following facts reasonably explain the need for further time. See TEX. R. APP. P. 10.5(b)(1)(c). a. As noted in Appellant’s first motion for extension, Appellant’s attorney, Katherine Armstrong, was on vacation from June 20, 2015 to June 30, 2015. Since her return from vacation, her time has been significantly occupied with numerous pending matters and deadlines, including on-going briefing and discovery responsibilities in a federal multi- district litigation; preparation for an upcoming deposition; post-judgment briefing in an insurance litigation pending in Oklahoma; and briefing regarding discovery disputes in several insurance litigations pending in Texas. 10. Counsel for appellant has conferred with counsel for appellees, Jennifer Bruch Hogan, and appellees are unopposed to the requested extension. 11. This request is not sought for delay, but in order that justice may be done. PRAYER Appellant, State Farm Lloyds, asks this court to grant an extension of 10 days, until July 23, 2015, to file its reply brief. Appellant also prays for any other relief to which it may be entitled. Dated: July 7, 2015 Respectfully submitted, /s/ David V. Jones /s/ Katherine Armstrong David V. Jones Katherine Armstrong State Bar No. 10869825 State Bar No. 01321400 dvj@jao-law.com KatherineArmstrong@quinnemanuel.com Benjamin G. Kemble QUINN EMANUEL URQUHART & SULLIVAN, State Bar No. 24050864 LLP Edward J. Batis, Jr. 51 Madison Avenue, 22nd Floor State Bar No. 01915470 New York, NY 10010 JONES, ANDREWS & ORTIZ, P.C. (212) 849-7000 – Telephone 10100 Reunion Place, Suite 600 (212) 849-7100 – Facsimile San Antonio, Texas 78216 (210) 344-3900 – Telephone (210) 366-4301 – Facsimile Attorneys for Appellant State Farm Lloyds CERTIFICATE OF CONFERENCE Counsel for appellant has conferred with counsel for appellees, Jennifer Bruch Hogan, and the appellees are unopposed to this motion for extension of time to file appellant’s reply brief. DATED: July 7, 2015 /s/ Katherine Armstrong Katherine Armstrong CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above Second Unopposed Motion for Extension of Time to File Appellant’s Reply Brief has been served on the following individual(s) by the method(s) indicated, on this, the 7th day of July 2015, as follows: Ms. Jennifer Bruch Hogan Mr. Richard P. Hogan, Jr. HOGAN & HOGAN Penzoil Place 711 Louisiana, Suite 500 Houston, TX 77002 (713) 222-8880 – Telephone (713) 222 8810 – Facsimile Email: jhogan@hoganfirm.com Email: rhogan@hoganfirm.com Via E-Filing Mr. J. Steve Mostyn THE MOSTYN LAW FIRM 3810 West Alabama Street Houston, TX 77027 (713) 861-6616 – Telephone (713) 861-8084 – Facsimile Email: jmostyn@mostynlaw.com Via E-Filing Mr. E. Hart Green Mr. Mitchell A. Toups WELLER, GREEN, TOUPS & TERRELL, L.L.P. P.O. Box 305 Beaumont, TX 77704 (409) 838-0101 – Telephone (409) 832-8577 – Facsimile Email: hartgr@wgttlaw.com Email: matoups@wgttlaw.com Via E-Filing /s/ Katherine Armstrong Katherine Armstrong