ACCEPTED
14-14-00649-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
1/29/2015 4:53:04 PM
CHRISTOPHER PRINE
CLERK
No. 14-14-00649-CV
_________________________________________________________________
FILED IN
14th COURT OF APPEALS
In the Court of Appeals HOUSTON, TEXAS
for the Fourteenth District of Texas 1/29/2015 4:53:04 PM
at Houston CHRISTOPHER A. PRINE
Clerk
__________________________________________________________________
DAVID L. GLASSEL,
Appellant,
v.
SEAMLESS OPERATING GROUP, LLC INDIVIDUALLY AND
DERIVATIVELY ON BEHALF OF CHEMICAL FREE SOLUTIONS, LLC,
AND CEDAR OIL SOLUTIONS, LLC
Appellees
On Appeal from the 189th Judicial District Court of Harris County, Texas
Trial Court Cause No. 2012-41601
APPELLANT DAVID L. GLASSEL’S MOTION TO EXTEND TIME
FOR FILING OF APPELLANT’S BRIEF
TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
Pursuant to Texas Rule of Appellate Procedure 26.3, Appellant David L.
Glassel files this Motion for Extension of Time to File his Appellant’s Brief, which
complies with Rule 10.5(b), and respectfully shows the Court as follows:
1. This is an appeal from the final order in Cause No. 2012-41601;
Seamless Operating Group, LLC et al v. David L. Glassel et al; In the 189th
Judicial District Court of Harris County, Texas.
2. The current deadline for Mr. Glassel’s Appellant’s Brief is Friday,
January 30, 2015.
3. Mr. Glassel was pro se at trial and in this appeal until he was able to
engage the undersigned counsel, who has appeared contemporaneous with the
filing of this motion on January 29, 2015.
4. This is Mr. Glassel’s second request for an extension of time. Mr.
Glassel previously requested a 30-day extension to allow him to engage counsel,
which the Court granted.
5. Mr. Glassel seeks an extension of time until Monday, March 2, 2015,
which would be a 32-day extension, to allow his counsel to review the record and
the law, and to draft a brief that would assist the Court regarding Mr. Glassel’s
issue on appeal. Mr. Glassel was previously unable to secure representation due to
the complexity of the matter on appeal and insufficient funds. The undersigned
counsel does not have sufficient time to properly prepare a brief to the Court
without the requested extension.
6. Mr. Glassel brings this motion pursuant to Texas Rules of Appellate
Procedure 38.6(d) and in compliance with Rule 10.5(b).
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7. Mr. Glassel does not seek this extension for the purposes of delay but
only so that justice may be service.
PRAYER
For all these reasons, Appellant David L. Glassel respectfully requests a 32-
day extension of time for filing his Appellant’s Brief until Monday, March 2, 2015
and for such further or additional relief to which he may be entitled.
Respectfully submitted,
/s/George F. May/
________________________________
George F. May
TBA No. 24037050
TWOMEY | MAY, PLLC
2 Riverway, 15th Floor
Houston, Texas 77056
(713) 659-0000 [Telephone]
(832) 201-8485 [Telecopier]
gmay@twomeymay.com
Attorneys for Appellant
David L. Glassel
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CERTIFICATE OF CONFERENCE
I, George F. May, counsel for Appellant David L. Glassel, do hereby certify
that I have conferred with Appellees’ counsel Travis Vargo regarding Appellant’s
second request for extension of time to file his Appellant’s Brief and Mr. Vargo
indicated to me that he would confer on the matter but, at the time of this filing, I
have not heard from Mr. Vargo so this motion is filed assuming Appellees oppose
Appellant’s request.
/s/ George F. May/
George F. May
CERTIFICATE OF SERVICE
As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), (e), I certify
that I have served this document on all other parties, which are listed below on
January 29, 2015 as follows:
Travis B. Vargo
FRIDGE & RESENDEZ LLC
3000 Smith St.
Houston, Texas 77006
(713) 226-9100 – Phone
(713) 226-9800 – Fax
tvargo@frw-law.com
Attorney for Appellees
By (check all that apply)
personal delivery
mail
commercial delivery service
X fax, email, or electronic service
/s/ George F. May/
George F. May
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Date: January 29, 2015
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