ACCEPTED
14-14-00859-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
8/27/2015 4:36:05 PM
CHRISTOPHER PRINE
CLERK
No. 14-14-00859-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
8/27/2015 4:36:05 PM
FOR THE FOURTEENTH DISTRICT OF TEXAS
CHRISTOPHER A. PRINE
Clerk
AMERICAN RISK INSURANCE COMPANY, INC.
Appellant
v.
VERONICA SERPIKOVA
Appellee
Appeal from Cause No. 2013-14955
TH
In the 80 Judicial District Court of Harris County, Texas
APPELLEE’S UNOPPOSED MOTION TO EXTEND TIME
TO FILE BRIEF
J. Beverly
State Bar No. 02277280
jb@dowgolub.com
Kenneth H. Holt
State Bar No. 00793012
kholt@dowgolub.com
DOW, GOLUB, REMELS &BEVERLY LLP
9 Greenway Plaza, Suite 500
Houston, Texas 77046
Telephone: (713) 526-3700
Facsimile: (713) 526-3750
ATTORNEYS FOR APPELLEE
VERONIKA SERPIKOVA
AUGUST 27, 2015
APPELLEE’S UNOPPOSED MOTION
TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
Appellee, Veronika Serpikova1, pursuant to TEX. R. APP. P. 10.5(b) and
38.6(d), respectfully moves this Court for an extension of time to file her brief and
in support thereof would show as follows:
Introduction
This is an appeal by American Risk Insurance Co., Inc. from the Final
Judgment of the Court in the case styled Cause No. 2013-14955, Veronika Serpikova
v. American Risk Insurance Co., Inc.; in the 80th Judicial District Court of Harris
County, Texas.
The trial court signed a final judgment on July 25, 2014. Appellant filed its
notice of appeal on October 23, 2014.
Appellee’s brief is currently due on August 31, 2015. Appellee now seeks a
30-day extension of time until September 30, 2015, in which to file her brief.
This is Appellee’s first request for an extension of time to file her brief.
Because this case has not yet been set for submission or hearing, no unnecessary
delay will result from granting this extension.
1
Appellee’s name was misspelled as “Veronica Serpikova” in Appellant’s Notice of Appeal.
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Certificate of Conference
Counsel for Appellee conferred with Kevin F. Risley, lead counsel for
Appellant, on August 27, 2015 by electronic mail and he is not opposed to this
motion or the relief sought herein.
Argument and Authorities
This Court may extend the time to file a brief under the authority of TEX. R.
APP. P. 38.6(d).
Appellee relies on the following facts to reasonably explain her need for an
extension of time to file her brief:
1. Counsel for Appellee was preparing for a Court-ordered mediation
scheduled on August 7, 2015, in Cause No. 2014-62516, Williams
Temple Church of God in Christ, Inc., et al. v. Norman White, et al.; in
the 11th Judicial District Court of Harris County, Texas.
2. Counsel for Appellee has been preparing a Reply to a Motion for
Summary Judgment due on August 14, 2015 and for a hearing
scheduled on August 21, 2015, in a case styled Cause No. 2013-00532,
Irving C. Stern, Trustee, et al. v. New TK Coatings, LLC d/b/a Turn-
Key Coatings, et al.; in the 80th Judicial District Court of Harris County,
Texas.
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3. Counsel for Appellee has been preparing motions for judgment
notwithstanding the verdict and a motion for indemnification scheduled
for hearing on August 17, 2015, in Cause No. 2014-62516, Williams
Temple Church of God in Christ, Inc., et al. v. Norman White, et al.; in
the 11th Judicial District Court of Harris County, Texas.
4. Counsel for Appellee has been preparing a reply brief which was due
August 24, 2015 in a case styled Cause No. 14-14-00660-CV, Michael
Silberstein, et al. v. Trustmark National Bank f/k/a Republic National
Bank; in the Fourteenth District Court of Appeals at Houston, Texas.
5. Co-Counsel for Appellee, who is assisting with the brief, has been
preparing for and taking depositions set for August 26 and 27, 2015, in
a case styled Cause No. 2014-72223, Coastal Energy Company v.
Griffith; in the 152nd Judicial District Court of Harris County, Texas.
6. Counsel for Appellee has been preparing a Reply Brief due September
11, 2015, in a Case Nos. 14-1746 and 15-1390, styled Pei-Herng Hor
v. Ching-Wu “Paul” Chu, in the United States Court of Appeals for the
Federal Circuit.
Conclusion and Prayer
For the reasons stated, Appellee Veronika Serpikova requests that the Court
grant an extension of time to file Appellee’s brief until September 30, 2015.
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Respectfully submitted,
DOW GOLUB REMELS & BEVERLY, LLP
By: /s/ J. Beverly
J. Beverly
Texas Bar No. 02277280
jb@dowgolub.com
Kenneth H. Holt
Texas Bar No. 00793012
kholt@dowgolub.com
9 Greenway Plaza, Suite 500
Houston, Texas 77046
Tel. (713) 526-3700
Fax (713) 526-3750
ATTORNEYS FOR APPELLEE
VERONIKA SERPIKOVA
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Appellee’s Unopposed Motion
to Extend Time to File Brief was sent to:
Kevin F. Risley
Jamie R. Carsey
THOMPSON, COE, COUSINS & IRONS, L.L.P.
One Riverway, Suite 1400
Houston, Texas 77056-1988
Spencer E. Dunn
4669 Southwest Freeway, Suite 700
Houston, Texas 77027
ATTORNEYS FOR APPELLANT
AMERICAN RISK INSURANCE CO. INC.
by electronic service on August 27, 2015.
/s/ J. Beverly
J. Beverly
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