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_________