Farha Rasheed v. Texas Fair Plan Association

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ACCEPTED 01-15-00887-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/22/2015 3:46:19 PM CHRISTOPHER PRINE CLERK No. 01-15-00887-CV _________________________________ FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST JUDICIAL DISTRICT 12/22/2015 3:46:19 PM HOUSTON, TEXAS CHRISTOPHER A. PRINE _________________________________ Clerk FARHA RASHEED, APPELLANT, V. TEXAS FAIR PLAN ASSOCIATION, APPELLEE. ____________________________________________________________ On Appeal from the 268th Judicial District Court of Fort Bend County, Texas The Honorable Brady G. Elliott Trial Court Cause No. 13-DCV-205335 ____________________________________________________________ APPELLEE TEXAS FAIR PLAN ASSOCIATION’S MOTION FOR EXTENSION OF TIME ____________________________________________________________ TO THE HONORABLE COURT OF APPEALS: Appellee Texas Fair Plan Association files this Motion for Extension of Time pursuant to Texas Rule of Appellate Procedure 10.5(b) and would respectfully show the following: I. Appellant Farha Rasheed filed her Appellant’s Brief on December 4, 2015. Appellee’s Brief is presently due on January 4, 2016. II. Appellee seeks a thirty (30) day extension of time to file its Appellee’s Brief because of the intervening holiday and the undersigned counsel’s prior commitment to other litigation matters. III. This is Appellee’s first request for an extension of time to file Appellee’s Brief. IV. This request for an extension of time is not sought for the purpose of delay only, but so that justice may be done. PRAYER WHEREFORE PREMISES CONSIDERED, Appellee, Texas Fair Plan Association, respectfully prays that this Court grant its Motion and extend the due date for Appellee’s Brief to February 3, 2016. 2 Respectfully submitted, GERMER PLLC By:_____________________________ DALE M. “RETT” HOLIDY State Bar No. 00792937 rholidy@germer.com KELLI B. SMITH State Bar No. 24008053 ksmith@germer.com SANDRA HOWARD State Bar No. 24007394 showard@germer.com Three Allen Center 333 Clay Street, Suite 4950 Houston, Texas 77002 (713) 650-1313 – Telephone (713) 739-7420 – Facsimile ATTORNEYS FOR APPELLEE, TEXAS FAIR PLAN ASSOCIATION CERTIFICATE OF CONFERENCE In accordance with Texas Rule of Appellate Procedure 10.1(a)(5), I certify that Appellee’s counsel conferred with Appellant’s counsel regarding the relief requested in the foregoing Motion for Extension of Time, and it is opposed. DALE M. “RETT” HOLIDY 3 CERTIFICATE OF SERVICE I hereby certify that on the 22nd day of December, 2015, a true and correct copy of Appellee’s Motion for Extension of Time was forwarded to all known counsel of record pursuant to the Texas Rules of Appellate Procedure. DALE M. “RETT” HOLIDY 4