ACCEPTED
14-15-00028-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/16/2015 5:39:13 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00028-CV
FILED IN
14th COURT OF APPEALS
IN THE FOURTEENTH COURT OF APPEALS,
HOUSTON, TEXAS
HOUSTON, TEXAS 2/17/2015 9:15:00 AM
CHRISTOPHER A. PRINE
Clerk
MICHAEL JUSTIN JACOBS,
APPELLANT
V.
ADANA ALT,
APPELLEE
UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
Pursuant to Rule 38.6(a) and Rule 10.5(b) of the Texas Rules of Appellate
Procedure, Michael Justin Jacobs, the Appellant in this proceeding, seeks an
extension of the deadline for filing his Appellant’s Brief with this Court. In
support of his request for an extension of time, Michael Justin Jacobs submits the
following:
1. In compliance with Rule 10.5(b) of the Texas Rules of Appellate
Page 1 of 4
Procedure, Appellant’s counsel advises this Court of the following matters:
(A) Appellant’s Brief is due to be filed with the Clerk of this
Court on February 26, 2015.
(B) Appellant is seeking an extension of time for filing his Appellant’s
Brief from February 26 2015 until March 28, 2015 (30 days).
(C) the number of previous extensions granted regarding the
item in question - None
(D) the facts reasonably relied on to reasonably explain the
need for an extension are described below.
2. The undersigned counsel has had numerous other commitments,
including hearings, mediations, and discovery deadlines, that have prevented
counsel from preparing a working draft of Appellant’s Brief to date. Additionally,
the undersigned counsel has a full-day deposition and a two-day trial scheduled
during the ten days that, along with witness and trial preparation, make timely
preparation of the Appellant’s Brief impossible.
3. The undersigned counsel respectfully represents to this Court that
additional time is needed to properly brief and explain the issues in a clear and
concise manner.
4. All facts stated herein are within the personal knowledge of the
Page 2 of 4
undersigned counsel.
WHEREFORE, ABOVE PREMISES CONSIDERED, the undersigned
counsel on behalf of Michael Justin Jacobs respectfully prays that upon
consideration of the matters set forth herein, this Court extend the deadline for
filing of the Appellant’s Brief to March 28, 2015.
Michael Justin Jacobs also respectfully prays for such other and further relief
to which he may be justly entitled.
Respectfully submitted,
FRANKENBERRY LAW FIRM
4425 S. Mopac Expressway, Suite 105
Austin, Texas 78735
512-252-9937
Fax: 512-852-5937
paige@frankenberrylaw.com
By: ______________________________
Paige Frankenberry
State Bar No.: 24074226
ATTORNEY FOR APPELLANT,
MICHAEL JUSTIN JACOBS
CERTIFICATE OF CONFERENCE
Pursuant to Rule 10.1(a)(5) of the Texas Rules of Appellate Procedure, the
undersigned counsel advises this Court that prior to making this request, she
contacted Appellee’s attorney of record, Robert D. Ettinger, about the merits of the
motion, and he does not oppose Appellant’s Motion for Extension of Time.
Page 3 of 4
_________________________
Paige Frankenberry
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been served
on opposing counsel, Robert D. Ettinger, P.O. Box 50323, Austin, Texas 78763 via
email to robert@ettlaw.com on this 17th day of February, 2015.
__________________________
Paige Frankenberry
Page 4 of 4
Michael Justin Jacobs v. Adana Alt
Combined Opinion