Country Title , L.L.C. v. Morenike Jaiyeoba

ACCEPTED 01-14-00931-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 7/22/2015 4:09:31 PM CHRISTOPHER PRINE CLERK NO. 01-14-00931-CV IN THE FIRST COURT OF APPEALS FILED IN 1st COURT OF APPEALS AT HOUSTON, TEXAS HOUSTON, TEXAS 7/22/2015 4:09:31 PM CHRISTOPHER A. PRINE Clerk COUNTRY TITLE, L.L.C., Appellant VS. MORENIKE JAIYEOBA, Appellee On Appeal from 268th Judicial District Court Fort Bend County, Texas Cause 07-DCV-159705 ________________________________________________ SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF [UNOPPOSED] ________________________________________________ TELTSCHIK!GRUBBS L.T. Bradt #02841600 Betsy L. Grubbs #24032259 14015 Southwest Freeway, Suite 4 Sugar Land, Texas 77478 (281) 201-0700 Fax: (281) 201-1202 ltbradt@flash.net grubbs@tlaw.us Attorneys for Appellee Page 1 of 4 Appellee asks the Court to extend the time to file Appellee’s Brief and respectfully shows as follows: 1. Appellant is COUNTRY TITLE, L.L.C.; appellee is MORENIKE JAIYEOBA. 2. The 268th Judicial District Court of Fort Bend County, Texas, signed its Final Judgment on August 19, 2014, in favor of appellee and against appellant. 3. On May 7, 2015, the Appellant’s Brief was filed. 4. The Appellee’s brief was due July 9, 2015, and this Motion for Extension of Time is filed within the 15 day period to file the brief. 5. Appellee needs an extension of time due Counsel’s schedule: a. June 12, 2015, prepared for and attended pre-trial conference on Silkowski v. Joern, Cause No. 09CV1968, pending in the 212th Judicial District Court of Galveston County, Texas, assigned for June 22, 2015. b. June 15 - June 29, Prepared for and presented trial to jury verdict, Silkowski v. Joern, Cause No. 09CV1968, pending in the 212th Judicial District Court of Galveston County, Texas. Trial began, June 22; verdict returned, June 29. c. Assisted in the research and drafting of a Petition for Page 2 of 4 Discretionary Review in four matters, PDR Granted June 10, 2015, Extension granted June 22, and brief now due July 27, 2015. d. Assisted in the research and drafting of a Petition for Writ of Certiorari to the Court of Criminal Appeals, filed July 14, 2015. e. Appellee requests an additional 30 days to complete the brief, to, through and including August 9, 2015. CERTIFICATE OF CONFERENCE 6. A conference was held with Leslee Haas on the merits of this motion and opposing counsel is unopposed to the extension requested. D. Prayer 7. For these reasons, Appellee asks that the Court grant an extension of time to file the brief until August 9, 2015. Appellee prays for general relief. Respectfully Submitted, TELTSCHIK-GRUBBS, P.L.L.C. /s/ L.T. “Butch” Bradt L.T. Bradt #02841600, ltbradt@flash.net Betsy L. Grubbs #24032259 14015 Southwest Freeway, Suite 4 Sugar Land, Texas 77478 (281) 201-0700 Fax: (281) 201-1202 ATTORNEYS FOR MORENIKE JAIYEOBA Page 3 of 4 CERTIFICATE OF SERVICE I, the undersigned attorney, certify that a true and correct copy of the foregoing Second Motion to Extend time to file Appellee’s Brief was served in accordance with Texas Rules of Appellate Procedure Rule 9.5, on: Ms. Leslee Haas Brianne W. Richardson LeClair Ryan 1233 West Loop South, Suite 1000 Houston, Texas 77027 Via Facsimile to: (713) 650-0027 on July 22, 2015. /s/ L.T. “Butch” Bradt L.T. “Butch” Bradt Page 4 of 4