ACCEPTED
01-14-00869-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/24/2015 12:41:50 PM
CHRISTOPHER PRINE
CLERK
APPEAL NO. 01-14-00869-CV
IN THE COURT OF APPEALS FILED IN
1st COURT OF APPEALS
FIRST JUDICIAL DISTRICT HOUSTON, TEXAS
HOUSTON, TEXAS 2/24/2015 12:41:50 PM
CHRISTOPHER A. PRINE
Clerk
RICHARD MAKOVER, Appellant
vs.
RANDY S. TURRENTINE, Appellee
APPELLEE’S MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:
Appellee Randy S. Turrentine (“Appellee”) moves to extend time under
TEX. R. APP. P. 10.5(b) to file his Appellee’s Brief, and in support of this Motion
would respectfully show as follows:
1. The attorney for the Appellant was contacted on February 24, 2015,
but has not received a response as of the filing of this Motion.
2. Appellee’s Brief is due on March 4, 2015. There have been no prior
extensions sought with respect to the filing of Appellee’s Brief.
3. The commitments of the undersigned attorney are such that a 30-day
extension of time is necessary in order to properly prepare Appellee’s Brief. The
1
commitments of the undersigned are, in addition to a number of depositions to be
held out of state, as follows:
• February 25, 2015: Trial in Cause No. CV-0072161; Robert Keith
Downs vs. John G. Kent and Jan Kent; in the County Civil Court at
Law No. 3 of Galveston County, Texas
• March 2, 2015: Trial in Cause No. 2013-33908; Steve Montoya vs
Chulas Sports Cantina Management LLC, et al; in the 113th Judicial
District Court of Harris County, Texas
• March 9, 2015: Trial of Docket No. 14-05423; Mariana Orozco OBO
Filiberto Serna, Jr. vs. Filser Construction and Aries Building
Systems; in District 7, Office of Louisiana Worker’s Compensation
• March 16, 2015: Cause No. 2014-19441; International
Demographics, Inc. d/b/a The Media Outlet vs. Higginbotham
Associates, Inc.; in the 281st Judicial District Court of Harris County,
Texas
• March 19, 2015: Petition for Writ of Certiorari to U.S. Supreme
Court, appealing from USCA Case No. 14-20188; Larry Bishop, et al.
v. Texas Dept. of Public Safety, et al.; 5th Circuit Court of Appeals
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellee Randy S. Turrentine
requests that his time to file a Brief be extended to April 3, 2015, and for such
other relief to which Appellee may be entitled.
2
Respectfully submitted,
MURRAY | LOBB, PLLC
By: /s/ Kyle L. Dickson
Kyle L. Dickson
State Bar No. 05841310
700 Gemini, Suite 115
Houston, Texas 77058
Ph: (281) 488-0630
Fax: (281) 488-2039
Email: kdickson@murray-lobb.com
ATTORNEYS FOR APPELLEE
RANDY S. TURRENTINE
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing document has
been forwarded to all parties and/or counsel of record in accordance with the Texas
Rules of Appellate Procedure on day February 24, 2015.
/s/ Kyle L. Dickson
Kyle L. Dickson
Ronald Julius Smeberg BY FAX TO (210) 598-7357 AND/OR
The Smeberg Law Firm, PLLC BY ELECTRONIC SERVICE
2010 W. Kings Hwy.
San Antonio, Texas 78201
3