ACCEPTED
01-15-00529-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/3/2015 12:38:58 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00529-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
FOR THE FIRST DISTRICT OF TEXAS
8/3/2015 12:38:58 PM
AT HOUSTON
CHRISTOPHER A. PRINE
Clerk
NACE INTERNATIONAL,
Appellant
v.
MAURICE JOHNSON AND E&M ENTERPRISES, INC.,
Appellees
Appealed from the 215th Judicial District Court
Harris County, Texas
APPELLEES’MOTION TO EXTEND TIME TO FILE APPELLEES’S BRIEF
Grealish & McZeal, PC
Marcellous S. McZeal
State Bar No. 00798368
SBN: 00798368
700 Louisiana Street, 48th Floor
Houston, Texas 77002
Telephone: (713) 255-3234
Facsimile: (713) 783-2502
ATTORNEYS FOR APPELLEESES,
Maurice Johnson & E&M Enterprises,
Inc.
TO THE HONORABLE FIRST COURT OF APPEALS:
Appellees respectfully requests this Court to extend the time in which to file Appellees’
Brief. NACE International, is the Appellant. Maurice Johnson & E&M Enterprises, Inc. are the
Appellees. Appellees’ Brief is due August 3, 2015. However, Appellees seek a 20 day extension
to file brief under the authority of T.R.A.P. 10.5(b).
The Court may extend time to file Appellees’ Brief under the authority of Texas Rules of
Appellate Procedure 10.5(b). This is Appellees’ first request for extension. Appellees seek an
extension of time to file Appellees’ Brief because the lead briefing attorney recently finished
closing a large corporate acquisition and there was not sufficient time to adequately, effectively
and diligently prepare Appellees’ Brief before the August 3, 2015 brief due date.
This is Appellees’ first request for an extension of time and Appellant, NACE
International by and through its attorney was unavailable to determine if it was opposed.
For the foregoing reasons, Appellees, Maurice Johnson & E&M Enterprises, Inc., request
this Court grant an extension of time in which to file his brief to on or about, August 24, 2015.
Respectfully Submitted,
GREALISH & McZEAL, PC
BY: /s/ Marcellous S. McZeal
Marcellous S. McZeal
State Bar No. 00798368
SBN: 00798368
700 Louisiana Street, 48th Floor
Houston, Texas 77002
Telephone: (713) 255-3234
Facsimile: (713) 783-2502
CERTIFICATE OF SERVICE
I hereby certify that on this the 3rd day of August 2015, a copy of the attached
Motion was forwarded to the counsel below via certified mail return receipt requested
pursuant to province of TEX.R.CIV.P. 21a
/s/ Marcellous S. McZeal
Marcellous S. McZeal
via facsimile @ (713) 535-5533
Robert Naudin
John L. Grayson
Cokinos, Bosien & Young
Four Houston Center
1221 Lamar, 16th Floor
Houston, Texas 77010
ATTORNEYS FOR APPELLANT
CERTIFICATE OF CONFERENCE
I hereby certify that I have made a good faith effort to confer with Appellant’s
counsel on August 3, 2015. I unsuccessfully telephoned and emailed Mr. Naudin, counsel
for Appellant, to determine if he was opposed to this motion. At the time of the filing of
this Motion, there was no response.
/s/ Marcellous S. McZeal
Marcellous McZeal
Nace International v. Maurice Johnson and E & M Enterprises, Inc.
Combined Opinion