ACCEPTED
01-14-00851-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/5/2015 1:57:02 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00851-CV
KORI LYNN PLOWMAN F/K/A IN THE FIRST FILED IN
KORI LYNN UGALDE 1st COURT OF APPEALS
HOUSTON, TEXAS
Appellant,
2/5/2015 1:57:02 PM
CHRISTOPHER A. PRINE
v. COURT OF APPEALS Clerk
Philip Andrew Ugalde
Appellee. HOUSTON, TEXAS
APPELLANT'S SECOND MOTION TO EXTEND TIME TO FILE BRIEF
Appellant asks the Court to extend the time to file brief.
A. Introduction
1. Appellant is Kori Lynn Plowman F/K/A Kori Lynn Ugalde. Appellee is
Philip Andrew Ugalde.
2. No rule provides a deadline to file this motion to extend. See Tex. R. App.
P. 38.6(d).
B. Argument & Authorities
3. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d)
to extend the time to file the brief
4. Appellant requests an additional 30 days to file her brief, extending the time
until March 9, 2015.
5. One extension has been granted to extend the time to file Appellants' brief
6. Appellant needs additional time to file her brief because appellant's counsel
has been involved in multiple district court cases, federal court cases and mediations.
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Appellants' counsel requires additional time to complete the drafting of the brief.
C. Conclusion
7. Appellant requires additional time to complete her brief.
D. Prayer
8. For these reasons, Appellant asks the Court to grant an extension of time to
file her brief until March 9, 2015.
Respectfully submitted,
ALLAN A. CEASE & ASSOCIATES, P.C.
/s/ Allan A. Cease
BY: Allan A. Cease
Texas Bar No. 04040550
35 Sugar Creek Center Blvd, Suite 300
Sugar Land, Texas 77478
Tel. 281-980-0909
Fax 281-980-1069
Attorney for Appellant,
Kori Lynn Plowman F/K/A Kori Lynn Ugalde
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VERIFICATION
STATE OF TEXAS
FORT BEND COUNTY
Before me, the undersigned notary, on this day personally appeared Allan A.
Cease, the affiant, a person whose identity is known to me. After I administered an
oath to affiant, affiant testified:
"My name is Allan A. Cease. I am capable of making this verification. I have
read the Appellant's Second Motion to Extend Time to File Brief The facts stated
in it are within my personal knowledge and are true and correct."
°MU
Allan A. Cease
aW
SWORN TO AND SUBSCRIBED BEFORE ME by Allan A. Cease on February
5, 2015.
NICOLE COX
'Ifs Notary Public, State of Texas
••
A „Lea-e
Th
NAry Public - State of Texas
My Commission Expires
October 24, 2017
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CERTIFICATE OF CONFERENCE
I certify that I have conferred withSteven P. Lindamood and he is unopposed to
this motion.
/s/ Allan A. Cease
Allan A. Cease
CERTIFICATE OF SERVICE
I certify that a copy of Appellant's Motion to Extend Time to File Brief was
served on Appellee, Philip Andrew Ugalde, through counsel of record, Steven P.
Lindamood of Connor & Lindamood, P.C., at 1221 Lamar Street, Ste. 1010, Houston,
Texas 77010, by telephonic document transfer to fax number 713-654-8115, on
February 5, 2015.
/s/ Allan A. Cease
Allan A. Cease
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