ACCEPTED
01-14-01015-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/9/2015 5:00:33 PM
CHRISTOPHER PRINE
CLERK
NO. 01-14-01015-CV
FILED IN
______________________________________________________________________________
1st COURT OF APPEALS
HOUSTON, TEXAS
4/9/2015 5:00:33 PM
IN THE COURT OF APPEALS CHRISTOPHER A. PRINE
FOR THE FIRST DISTRICT Clerk
HOUSTON, TEXAS
______________________________________________________________________________
SANDRA NZE
Appellant
V.
UCHENNA NWABUEZE
Appellee
______________________________________________________________________________
APPELLANT'S RESPONSE TO APPELLE'S OBJECTION TO
APPELLANT'S REQUEST FOR EXTENTION
Appellant, Sandra Nze, through counsel, Nwadi Nwogu requests the Court to grant
Appellant's request for Extension in this matter. This request is not sought for delay but that
justice may be done in this matter.
Appellant is Appellee's wife and the co-owner of the property where that she occupies
with her and Appellee's two children. Appellee also occupied this property beginning the year,
2002, until late last year when he discovered that his daughter had been diagnosed with cancer
and requires immediate surgery. Rather than provide medical care for his daughter, Appellee
initiated an eviction of his own entire family from their residence.
The property in question is community property and a Texas court is yet to divide the couple's
assets. A divorce proceeding is pending between the parties in this matter with the Fort Bend
District Court.
Appellee seeks to evict his wife and children one of whom is very sick and in need of
immediate surgical intervention from their rightful residential property since 2002.
Appellant and her children are not tenants as Appellee and counsel allege. They are the
rightful owners of the property the reason for this suit.
Appellee has not suffered a financial hardship as a result of his wife and children residing
in their rightful home.
Counsel requires reasonable time to do a due diligence review of this matter and
competently defend Appellant. Counsel requests the Court to kindly take into consideration that
Counsel has previously scheduled depositions and out of city trials through April 28, 2015.
Counsel requests that Appellant's Motion to Extend time to file Appellate Brief be
granted and the deadline for the filing of appellant's brief extended at least 30 days from April
28, 2015.
Respectfully submitted,
ODUNZE NWOGU LAW GROUP, P.C.
By: /s/ NWADI NWOGU
NWADI NWOGU
Texas Bar No. 24074826
6001 SAVOY DRIVE
SUITE 302
HOUSTON, Texas 77036
Tel. (713)334-8080
Fax. (713)334-3533
Email address: NWADI@ONLAWGROUP.COM
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
I certify that on April 9, 2015 a true and correct copy of this document was served by
facsimile transmission on Carlette White at 713-391-8724.
/s/ NWADI NWOGU
NWADI NWOGU