ACCEPTED
14-15-00845-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
12/10/2015 4:43:53 PM
CHRISTOPHER PRINE
CLERK
No. 14-15-00845-CV
IN THE COURT OF APPEALS FILED IN
14th COURT OF APPEALS
FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS
HOUSTON, TEXAS
AT HOUSTON 12/10/2015 4:43:53 PM
CHRISTOPHER A. PRINE
Clerk
RICHARD SAAD, JR.
Appellant,
V.
VRISELDA R. VALDEZ, ET AL.
Appellee
__________________________________________________________________
On Appeal from the 234th Judicial District Court of
Harris County, Texas Cause No. 2011-17650
__________________________________________________________________
APPELLANT’S FIRST UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
Robert J. Killeen, Jr.
State Bar No. 11407000
Robert C. Stern
State Bar No. 24053637
Gerald M. Johnson, III
State Bar No. 10722580
KILLEEN & STERN, P.C.
1811 Bering, Suite 120
Houston, Texas 77057
713.626.5100-telephone
713.626.4545-facsimile
rkilleen@killeen-law.com
Counsel for Appellant, Richard
Saad, Jr.
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
Appellant, Richard Saad, Jr., files this unopposed motion for extension of
time to file its brief on the merits. The current filing deadline for the brief is
December 14, 2015. Appellant requests a 30-day extension, for a new deadline of
January 13, 2016.
The reasons for this extension are that counsel for Appellant is also tasked
with (1) preparing an appellant’s brief in 09-15-00299-CV, National Security Fire
& Casualty Co., v. Rene Lampson and Justina Henriquez, in the Court of Appeals
for the Ninth Judicial District; filed July 30, 2015; (2) preparing an appellant’s
brief in 14-15-00714-CV, National Security Fire & Casualty Co., v. Ozier Hurst,
in the Court of Appeals for the Fourteenth Judicial District; filed August 21, 2015;
and (3) preparing an appellant reply brief in 14-15-00610-CV, South Winds
Express Construction, LLC v. D.H. Griffin of Texas, Inc., in the Court of Appeals
for the Fourteenth Judicial District, filed July 2, 2015.
No previous extensions have been granted, and the Court has authority to
extend the time to file a brief under Texas Rule of Appellate Procedure 38.6(d).
This extension is unopposed and is not sought for delay only. No party will be
prejudiced if it is granted. As set forth in the Certificate of Conference, Appellee
does not oppose the relief sought by this motion.
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For these reasons, Appellant, Richard Saad, Jr., prays that this Court grant
his Unopposed Motion for Extension of Time to File Reply Brief on the Merits,
extending the deadline to January 13, 2016.
Respectfully submitted,
KILLEEN & STERN, P.C.
By: /s/ Robert J. Killeen, Jr.
Robert J. Killeen, Jr.
Texas Bar No. 11407000
E-mail: rkilleen@killeen-law.com
Robert C. Stern
Texas Bar No. 24053637
E-mail: rstern@killeen-law.com
Gerald M. Johnson, III
State Bar No. 10722580
E-mail: tjohnson@killeen-law.com
1811 Bering Dr., Suite 120
Houston, Texas 77057
Office: (713) 626-5100
Fax: (713) 626-4545
ATTORNEYS FOR APPELLANT,
RICHARD SAAD, JR.
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CERTIFICATE OF CONFERENCE
On December 10th, 2015, the undersigned conferred with counsel for
Appellee, who stated that his client does not oppose the relief requested in this
motion.
/s/ Robert J. Killeen, Jr.
Robert J. Killeen, Jr.
CERTIFICATE OF SERVICE
On December 10, 2015 I electronically filed this First Unopposed Motion
for Extension of Time to File Brief with the Clerk using the eFile.TXCourts.gov
electronic filing system which will send notification of such filing to the following:
Hugh J. Plummer
Plummer and Farmer
3303 Louisiana Street, Suite 145
Houston, Texas 77006
Via Email: pplummer@plummerandfarmer.com
ATTORNEY FOR APPELLEE
VRISELDA R. VALDEZ, ET AL.
/s/ Robert J. Killeen, Jr.
Robert J. Killeen, Jr.
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