in the Matter of the Marriage of Lowell M. McCoy, Jr., and Karon K. Els

ACCEPTED
14-14-870-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
1/29/2015 3:02:59 PM
CHRISTOPHER PRINE
CLERK

14-14-870-CV
FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
IN THE FOURTEENTH COURT OF APPEALS FOR TEXAS
1/29/2015 3:02:59 PM
CHRISTOPHER A. PRINE
Clerk

LOWELL MCCOY, JR.
Appellant,

v.

KARON ELSE,
Appellee.

ON APPEAL FROM
300TH DISTRICT COURT
BRAZORIA COUNTY, TEXAS
CAUSE NO. 75438-F

UNOPPOSED MOTION TO EXTEND TIME TO
FILE APPELLANT’S BRIEF

TO THE JUSTICES OF THE FOURTEENTH COURT OF APPEALS:

Appellant asks to grant this motion for extension of time to file the Appellant’s

Brief for two weeks, to February 14, 2015.

1. The Appellant’s Brief was due January 29, 2015. This is the first such request.

2. Counsel for Appellant was stricken with the flu, and unable to work for a period

from December 21, to January 23.

3. Further, counsel for Appellant has oral argument before the 5 th Circuit on February

4th, 2015.
 4. This request is not made for mere delay, but so that a well reasoned and researched

brief may be submitted.

PRAYER

For all these reasons, appellant asks this Court grant an extension of time to file

the Appellant’s Brief to February 14, 2015.

Respectfully submitted,

_/s/ Savannah Robinson ________________
Savannah Robinson
Texas Bar No. 17108150
1822 Main
Danbury, TX 7534
Telephone: 979-922-8825
Savannahrobinson@aol.com
Attorneys for Appellant

CERTIFICATE OF CONFERENCE

I emailed Danielle Prade, the appellate attorney for appellee, who graciously does
not oppose this extension.

_/s/ Savannah Robinson ________________
Savannah Robinson

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Un-Opposed Motion to Extend Time to
File Appellant’s Brief was served on all counsel of record on January 29, 2015.

_/s/ Savannah Robinson_________________
Savannah Robinson

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 AFFIDAVIT

THE STATE OF TEXAS §
THE COUNTY OF HIDALGO §

BEFORE ME, The Undersigned Authority, on this day personally appeared

Savannah Robinson, the undersigned affiant, who, after being duly sworn, deposed and

stated on her oath the following:

1. “My name is Savannah Robinson. I an over the age of eighteen (18), of sound

mind, and I understand the taking of an oath. I have personal knowledge of every

statement made in this Affidavit, all of which statements are true and correct. I am

fully competent and authorized to testify as to the matters stated herein.

2. I have been retained to represent the Appellant in the above styled, attached and

referenced litigation.

3. I was ill over the holidays. I had three different respiratory illnesses, on a flu. I

went through three different medication episodes. I was not able to work a full

day from December 21 to January 23rd. As a result, all of my work was backed

up.

4. Briefing is something I prefer to do without distraction. The holidays would have

been a great time to work on this brief. I was prevented from working on this brief

during the holidays by my illnesses.

5. Additionally, I have oral argument before the Fifth Circuit on February 4 th. The

preparation, updated briefing, and participation during that week will make it

difficult to work on this brief before then.

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6. A two-week extension will not significantly delay this case. I reasonably believe

that with an exercise of diligence, I can get the brief completed by February 14,

2015.

7. Further affiant sayeth not.

__/s/Savannah Robinson______________
Savannah Robinson

SIGNED AND SWORN Before me on this the _29____ day of _January_____, 2015.

(seal) _/s/ Jeff Heumann__________________
Notary Public

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