ACCEPTED
01-15-00040-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/18/2015 2:23:03 PM
CHRISTOPHER PRINE
CLERK
In The Court of Appeals
for the
First District of Texas FILED IN
1st COURT OF APPEALS
______________________ HOUSTON, TEXAS
2/18/2015 2:23:03 PM
NO. 01-15-00040-CV CHRISTOPHER A. PRINE
______________________ Clerk
Raymond Shaw, Appellant
v.
Joseph Charles Lynch, Appellee
__________________________________________
On Appeal from the 284th Judicial District Court
Montgomery County, Texas
Trial Court Cause No. 12-12-13384-CV
___________________________________________
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
Pursuant to Rules 38.6(d) and 10.5(b) of the Texas Rules of
Appellate Procedure, Appellant Raymond Shaw moves for a sixty (60) day
extension of the deadline to file Appellant’s Brief and in support of this
motion states as follows:
1. The first deadline for filing Appellant’s Brief is February 20,
2015.
2. Counsel for Appellant’s two lawyer firm has had and continues
to have a busy trial schedule during the first three months of 2015,
including a week long trial in late January 2015. Additionally, Appellant’s
counsel did not realize until February 18, 2015 that a copy of the Clerk’s
record could not be accessed instantaneously online and thus is in the
process of obtaining the Clerk’s record in order to comply with Rule 38’s
requirement of supporting the Statement of the Case and Statement of
Facts with record references.
3. Appellant is seeking a modest sixty (60) day extension of the
deadline to April 21, 2015.
4. Appellant has not previously sought any extensions of the
deadline to file Appellant’s Brief.
Respectfully submitted,
THE GHEZZI LAW FIRM, PLLC
By: __________________________
John W. Ghezzi
Texas Bar No. 00792531
32731 Egypt Lane, Suite 704
Magnolia, TX 77354
Telephone: (281) 259-4993
Facsimile: (832) 645-7612
Email: John@GhezziLawFirm.com
ATTORNEYS FOR APPELLANT
RAYMOND SHAW
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CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify
that I have conferred, or made a reasonable attempt to confer, with all other
parties which are listed below about the merits of this motion with the
following results:
Heather M. Lytle, Attorney for Appellee
__ opposes motion
X does not oppose motion
__ agrees with motion
__ would not say whether motion is opposed
__ did not return my message regarding the motion
____________________________
John W. Ghezzi
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 February 18, 2015 as follows:
Heather M. Lytle
Attorney at Law
202 Travis Street, Suite 300
Houston, TX 77002
Attorney for Appellee
By: (check all that apply)
___ mail (First Class, Priority, Certified Mail)
X fax
X e-Service (through e-filing)
___ personal delivery / commercial delivery service
____________________________
John W. Ghezzi
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