Jennifer Mitchell and TCSM, LLC v. Turbine Resources Unlimited, Inc. and Tom George & International A., Inc.

ACCEPTED
14-15-00417-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/25/2015 1:33:05 PM
CHRISTOPHER PRINE
CLERK

No. 14-15-00417-CV

IN THE FOURTEENTH COURT OF APPEALS FILED IN
14th COURT OF APPEALS
at HOUSTON, TEXAS HOUSTON, TEXAS
11/25/2015 1:33:05 PM
CHRISTOPHER A. PRINE
JENNIFER MITCHELL and TCSM, LLC, Clerk
Appellants

v.

TURBINE RESOURCES UNLIMITED, INC.
Appellee

On appeal from the 61st District Court, Harris County, Texas,
Cause No. 2004-41286

APPELLEE’S FIRST MOTION FOR EXTENSION OF TIME

Appellee, Turbine Resources Unlimited, Inc., files this First Motion for Extension

of Time. In support thereof, Appellee would show the following:

1. This motion is time-sensitive. Appellees’ Brief is due today, November

25, 2015. Appellee recently retained the undersigned counsel to handle

these matters on this appeal. This is a consolidated appeal from (1) an

interlocutory appeal filed on May 4, 2015, and (2) an appeal from a final order, filed on

July 2, 2015. This Court consolidated both appeals under Cause No. 14-15-00417-CV.

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 2. Appellee has ordered supplements to the Clerk’s Record which will require

approximately 30 days considering the holiday season.

3. Appellee requests a 45 day extension to file their brief.

4. This is Appellee’s first request for an extension of time.

5. Appellee submits this motion not for the purposes of delay, but so that justice

may be done.

6. Appellants appeal concerns an order obtained by the Receiver. The second appealed

order denied appellant’s motion to modify the turnover order and claims that the Master’s

Reports are void. Riecke Baumann, Receiver and Master, is named as a party with an

interest in the outcome, but not as an appellee. Movant asks that the extension include

Receiver and Master, as neither Appellee nor Riecke Baumann has determined whether he

is an appellee and what his rights and duties are in this appeal.

Prayer

WHEREFORE, Appellee requests that all interested parties are granted a 45- day

extension to file their briefs; Appellee also prays for all other relief at law or in equity

to which the Court deems they may be justly entitled.

Respectfully submitted,

HOOVER SLOVACEK LLP

/s/ Brendetta A. Scott
Brendetta A. Scott

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 State Bar No. 24012219
scott@hooverslovacek.com
5051Westheimer, Suite 1200
Houston, Texas 77056

CERTIFICATE OF CONFERENCE

I certify that I contacted Appellant’s Counsel on November 24, 2015 to determine whether
counsel is opposed to this motion. The parties were not able to reach an agreement.

/s/ Brendetta A. Scott
Brendetta A. Scott

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the M o t i o n t o E x t e n d w a s served on
November 25, 2015 by electronic notification upon all counsel of record.

W. Joel Bryant Alan Cervenka Famose Garner
joel@bryantlaw.net cervenka2001@aol.com 10101 Southwest Fwy, Ste. 400
T. Kyle Bryant Attorney for Tom George and Houston, Texas 77074
kyle@bryantlaw.net International A, Inc. famosegarner@gmail.com
Counsel for Jennifer Mitchell
and TCSM, LLC. John Michael Owen Sonik
Vinson & Elkins Perdue Brandon Fielder Collins
1001 Fannin St., Ste. 2500 & Mott, LLP
Houston, Texas 77002 1235 North Loop West, Ste, 600
(713) 615 - 5231 (f) Houston, Texas 77008
jmichael@velaw.com (713) 862 - 1429 (f)
osonik@pbfcm.com

/s/ Brendetta A. Scott
Brendetta A. Scott

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