Herbert Jackson v. Patricia Jackson

ACCEPTED 01-14-00952-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/30/2015 1:13:15 PM CHRISTOPHER PRINE CLERK CASE NO. 01-14-00952-CV IN THE COURT OF APPEALS FOR T H E FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS FIRST SUPREME JUDICIAL DISTRICT 4/30/2015 1:13:15 PM CHRISTOPHER A. PRINE OF TEXAS AT HOUSTON Clerk HERBERT JACKSON Appellant PATRICIA JACKSON Appellee On Appeal from Cause No. 14-DCV-217167 328th Judicial District Court Fort Bend County, Texas MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: COMES NOW, HERBERT JACKSON, Defendant and request an extension to file Brief and would respectfully show as follows; Defendant, Herbert Jackson's attorney, Annie Briscoe, had a very extensive case load in last few months. Inadvertently she missed the notices showing when the brief was calendared. Therefore, Herbert Jackson is asking the court to grant a thirty day extension for counsel to prepare and file the petition on his behalf. WHEREFORE PREMISES CONSIDERED, counsel requests that the court grant her a thirty day extension in this matter in order for her to prepare and file the brief. Respectfully submitted, Annie P. Briscoe 1217 Prairie St., Suite 207 Houston, Texas 77002 713 270-8732 Telephone 713 227-0066 Telecopier TBN.:0300850 anniepump@yahoo.com CERTIFICATE OF SERVICE A copy of Motion to Extend Time was delivered to the following party(ies) by the means indicated on April 30,2015 Patricia Jackson VIA: Facsimile 713 960-0555 and Regular US Mail TO: Attorney Carolyn L. McElroy 5177 Richmond Ave, Suite 1275 Houston, Texas 77056 Annie P. Briscoe