Debbie Pattillo v. Sylvia Franco

ACCEPTED 14-15-00628-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/21/2015 3:16:46 PM CHRISTOPHER PRINE CLERK NO. 14-15-00628-CV __________________________________________ IN THE COURT OF APPEALS FOR THE FILED IN FOURTEENTH DISTRICT OF TEXAS 14th COURT OF APPEALS HOUSTON, TX HOUSTON, TEXAS __________________________________________10/21/2015 3:16:46 PM DEBBIE PATTILLO, CHRISTOPHER A. PRINE APPELLANT, Clerk V. SYLVIA FRANCO, APPELLEE. ___________________________________________________________ On Appeal from Cause No. 1024502 County Court at Law No. 4, Harris County, Texas Honorable Roberta Lloyd, Presiding Judge _____________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF _____________________________________________________________________________ TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS: Appellant, Debbie Pattillo, files this Unopposed Motion for Extension of Time to File Appellant’s Brief and in support shows the following: 1. Appellant’s Brief is due on October 22, 2015. Appellant requests an extension time of thirty days, to November 20, 2015 to file its Brief. 2. Appellant relies on the following facts as a reasonable explanation for the requested extension of time: The trial transcript was filed on 9/22/2015 but Appellant did not receive the trial transcript until October 13, 2015. Additionally, Appellant’s counsel was called for jury duty and has not had time to finsh the brief by the filing deadline of 10/22/2015. The extension is not sought for the purpose of delay. 3. The undersigned has conferred with opposing counsel, Kelli Smith who indicated there was no opposition to this request. WHEREFORE, ABOVE PREMISES CONSIDERED, Appellant DEBBIE PATTILLO, respectfully prays that this Honorable Court grant this motion for extension of time. APPELLANT'S MOTION FOR EXTENSION PAGE 1 OF 2 Respectfully submitted, BAILEY & GALYEN 4131 N. Central Expressway, Suite 860 Dallas, TX 75204 (214) 252-9099 - Office (214) 520-9941 – Facsimile srobelen@galyen.com- Email By: ___/s/ Scott G. Robelen . Scott G. Robelen Texas State Bar No.: 16990045 Federal Bar No.: 870867 ATTORNEY FOR PLAINTIFF CERTIFICATE OF CONFERENCE I certify that my assistant conferred with Kelli Smith on October 21, 2015 who indicated that this motion is unopposed. ___/s/ Scott G. Robelen . Scott G. Robelen CERTIFICATE OF SERVICE I certify that on 21st day of October, 2015, I served a copy of this motion by Facsimile at (713) 739-7420 and ECF to : Kelli Smith and Barbara Hachenburg who are the attorneys in charge for Appellee, SYLVIA FRANCO APPELLEE, and whose address is GERMER PLLC, Three Allen Center, 333 Clay Street, Suite 4950, Houston, TX 77002, (713) 650-1313 Telephone and (713) 739-7420 Facsimile ___/s/ Scott G. Robelen . Scott G. Robelen APPELLANT'S MOTION FOR EXTENSION PAGE 2 OF 2