Kyle Tauch, Tranquility Apartments General Corporation and Tranquility Apartments Ltd. v. Joel R. Scott

ACCEPTED
14-14-00169-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
1/29/2015 9:50:00 PM
CHRISTOPHER PRINE
CLERK

14-14-00169-CV
KYLE TAUCH, TRANQUILITY APARTMENTS
FILED IN
14th COURT OF APPEALS
GENERAL CORP AND HOUSTON, TEXAS
1/29/2015 9:50:00 PM
TRANQUILITY APPARTMENTS, LTD.
CHRISTOPHER A. PRINE
Clerk
Appellants
V.
JOEL SCOTT
Appellee

ON APPEAL TO THE FOURTEENTH COURT OF APPEALS
FROM THE 80TH JUDICIAL DISTRICT COURT
TRIAL CASE NO. 2011-21305-CV

MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ BRIEF

TO THE HONORABLE COURT OF APPEALS:
COME NOW KYLE TAUCH, TRANQUILITY APARTMENTS

GENERAL CORP. and TRANQUILITY APARTMENTS LTD, APPELLANTS in

this case, and file this, their Motion for Extension of Time to File Appellants’ Brief.

Appellants would show as follows:
 1.

Appellants are Kyle Tauch, Tranquility Apartments General Corp. and

Tranquility Apartments, Ltd.. Appellee is Joel R. Scott

2.

Judgment was signed Nov. 25, 2013 after a bench trial. A Request for Findings

of Fact and Conclusions of Law was filed on December 13, 2013 and a Motion to

Modify Judgment was filed on December 24, 2013. Notice of Appeal was filed in

the trial court on February 24, 2014. The Reporter’s Record was filed on October

17, 2014.

3.

Appellants’ Brief is due in the Court of Appeals today, January 29, 2015.

4.

Two previous extensions have been granted and counsel has never asked for

more than two extensions in twenty-two years, but counsel is too sick to proof what

she has written and needs a one-day extension.

5.

The extension requested is one (1) day, until January 30, 2015.

6.

The reason for this extension is so that Appellants’ counsel will do justice to

the task before her. The extension is not sought for delay.
 CONCLUSION & PRAYER

Appellants’ Counsel visited her daughter without knowing that her daughter

had a nasty cold. Counsel has completed a draft of the brief, but is too ill to properly

proof it.

WHEREFORE, PREMISES CONSIDERED, APPELLANTS ask this Court

to extend the deadline for filing their Brief one day, until January 30, 2015, and for

such other and further relief as may be just.

Respectfully submitted,

_____/s/ MB CHIMENE_________

THE CHIMENE LAW FIRM
Michele Barber Chimene
TBN 04207500
15203 Newfield Bridge Ln.
Sugar Land, TX. 77498
PH: (713) 474-5538; no fax
michelec@airmail.net

CERTIFICATE OF CONFERENCE

Appellants counsel tried to contact Chad Flores, counsel for Appellee, but it
is past working hours.

______/s/ MB CHIMENE________

CERTIFICATE OF SERVICE

A true and correct copy of this Motion for Extension has been served on
counsel for Appellee, Chad Flores at Beck Redden, 1221 McKinney, Ste. 4500,
Houston, TX. 77010, cflores@beckredden.com via ECF and email on this, the 29th
of January 2015. ______/s/ MB CHIMENE_________