Michael Quinn Sullivan v. Salem Abraham

FILED
14-0987
2/19/2015 11:29:51 AM
tex-4209022
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK

No. 14-0987

IN THE SUPREME COURT OF TEXAS

MICHAEL QUINN SULLIVAN,

Petitioner,

vs.

SALEM ABRAHAM,

Respondent.

ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR
THE SEVENTH DISTRICT AT AMARILLO
NO. 07-13-00296-CV

UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE RESPONDENT’S RESPONSE

Respectfully submitted,

LOVELL, LOVELL, NEWSOM & ISERN, L.L.P.
John H. Lovell, State Bar No. 12609300
John@lovell-law.net
Courtney Miller, State Bar No. 24055342
Courtney@lovell-law.net
112 West 8th Avenue, Suite 1000
Eagle Centre Building
Amarillo, Texas 79101-2314
Telephone: (806) 373-1515
Facsimile: (806) 379-7176

ATTORNEYS FOR RESPONDENT
February 19, 2015
TO THE HONORABLE SUPREME COURT OF TEXAS:

COMES NOW Respondent, Salem Abraham, and files this his Unopposed

Motion for Extension of Time to File Respondent’s Response. Respondent would

show the Court the following:

I.

1. Respondent Salem Abraham hereby requests an extension of time to file

the Respondent’s Response in the above-referenced case. Respondent’s Response is

due on Monday, February 23, 2015. Respondent requests a thirty (30) day extension

to Wednesday, March 25, 2105, to file his Response. Petitioner’s attorneys do not

oppose this motion, nor a thirty (30) day extension.

2. This is Respondent’s first request for an extension. Respondent relies

on the following facts as a reasonable explanation for the requested extension of time.

Respondent’s counsel, in addition to preparing a Response in this case also had to

devote time to a week long jury trial in Vernon, Texas in the matter of John

Mikkelsen, acting solely in his capacity as Trustee of the John Mikkelsen Trust v.

Herring Bancorp., Inc., C.C. Burgess and C. Campbell Burgess, Cause No. 24,955,

46th District Court, Wilbarger, Texas, and then, on February 11, 2015, Respondent’s

counsel’s wife had an undergo an unexpected surgery. An extension is necessary due

to John Lovell’s unexpected schedule changes due to his wife’s surgery and recovery

3. Work on Respondent’s Response began in a timely fashion. However, the

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unplanned matters set out above have made the proper completion of Respondent’s

Response by February 23, 2015 a problem.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Respondent, Salem Abraham,

prays that this Court grant his motion for a thirty (30) day extension of time to file

Respondent’s Response.

DATED this 19th day of February, 2015.

Respectfully submitted,

LOVELL, LOVELL, NEWSOM & ISERN, L.L.P.
John H. Lovell, State Bar No. 12609300
John@lovell-law.net
Courtney Miller, State Bar No. 24055342
Courtney@lovell-law.net
112 West 8th Avenue, Suite 1000
Eagle Centre Building
Amarillo, Texas 79101-2314
Telephone: (806) 373-1515
Facsimile: (806) 379-7176

By:/s/ John H. Lovell
John H. Lovell

ATTORNEYS FOR RESPONDENT

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 CERTIFICATE OF CONFERENCE

As required by Tex. R. App. P. 10.1(a)(5), I certify that I have conferred with
Petitioner’s counsel, Joe Nixon, who indicated that this motion is unopposed.

By:/s/ Courtney D. Miller
Courtney D. Miller

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was delivered,
as certified below, this 19th day of February, 2015 to:

James E. “Trey” Trainor III Via E-mail and Regular Mail
Joseph M. Nixon
BEIRNE, MAYNARD & PARSONS, LLP
401 W. 15th Street, Suite 845
Austin, Texas 78701

By:/s/ John H. Lovell
John H. Lovell

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