Rajinder Singh, Rita Kaur, Rajiv Chhabra and Gauri Chhabra v. Slawomir J. Skibicki and a & Skipol, Inc.

ACCEPTED 01-14-00825-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 3/20/2015 12:10:06 AM CHRISTOPHER PRINE CLERK 01-14-00825-CV FILED IN __________________________________ 1st COURT OF APPEALS HOUSTON, TEXAS 3/20/2015 12:10:06 AM IN THE CHRISTOPHER A. PRINE COURT OF APPEALS FOR THE Clerk FIRST JUDICIAL DISTRICT OF TEXAS AT HOUSTON, TEXAS ____________________________________ RAJINDER SINGH AND RITA KAUR, RAJIV CHHABRA AND GAURI CHHABRA, APPELLANTS VS. SLAWOMIR J. SKIBICKI AND A & SKIPOL, INC., A TEXAS CORPORATION, APPELLEES Appealed from the 11TH DISTRICT COURT of Harris County, Texas Trial Court Cause No. 2013-76488 _______________________________________ APPELLANTS’ SECOND MOTION TO EXTEND TIME FOR FILING APPELLANT’S BRIEF _______________________________________ TO THE HONORABLE JUSTICES OF SAID COURT: COMES NOW the Appellants, RAJINDER SINGH AND RITA KAUR and files this their SECOND Motion to Extend Time for Filing Appellant’s Brief and would respectfully show the following: 1. Appellant’s brief per the courts order is March 20, 2015(30 days after the later of either the date of the clerk’s record filed or the date of the reporter’s record filed.) 2. The complete record was filed on February 17, 2015 3. The courts online calendar indicates the deadline was on March 17, 2015. 4. No rule provides a deadline to file this motion to extend. See Tex. R. App. P. 38.6(d). 5. Although mediation was ordered, neither party has mediated at this time. 6. It is unclear as to the reason the online deadline contradicts the Rules, the Court’s Order, and the Notice, however Appellants file this motion in abundance of caution. Appellants respectfully request the deadline for filing their brief be set for March 20, 2015, which is thirty days for the date the complete record was filed. 7.Contemporaneously with filing this Motion, Appellants are also filing their Brief. WHEREFORE PREMISES CONSIDERED, APPELLANTS, RAJINDER SINGH and RITA KAUR , pray that this Court extend the time in which to file their Brief and accept Appellants Brief, file contemporaneously with this motion as timely filed. Respectfully submitted, _____________________________ “DANIEL” CHUNG LEE State Bar No. 24053793 C.Y. Lee Legal Group, PLLC 1305 Prairie St. Ste 300 Houston, Texas 77002 T: (682)551-8506 F: (713)223-0755 cyleelaw@gmail.com ATTORNEYS FOR Rajinder Singh and Rita Kaur CERTIFICATE OF CONFERENCE Jeremy Roberts, counsel for Appellees who states that he is opposed to this motion. Dated this 20th day of March, 2015. _________________________________ “Daniel” Chung Lee CERTIFICATE OF SERVICE I hereby certify that on this date a true and correct copy of the foregoing document was served upon all parties through their attorneys of record, with said service being effectuated by the following method: ___ Certified Mail, Return Receipt Requested ___ Telecopy X Eservice ___ Hand Delivery ___ Regular Mail, Postage Prepaid Dated this 20th day of March, 2015. _________________________________ “Daniel” Chung Lee