in the Interest of K.S., K.S., and C.S., Children

ACCEPTED 14-15-00008-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/25/2015 6:53:07 PM CHRISTOPHER PRINE CLERK In the COURT OF APPEALS FOR THE Fourteenth District of Texas FILED IN 14th COURT OF APPEALS ____________ HOUSTON, TEXAS 6/25/2015 6:53:07 PM NO. 14-15-00008-CV CHRISTOPHER A. PRINE Clerk ____________ IN THE INTEREST OF K.S., K.S., AND C.S. MINOR CHILDREN ______________________________________ On Appeal from the 309th District Court Harris County, Texas Trial Court Cause No. 2011-55905 ________________________________________________ APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF E. CHUDLEIGH – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 1 OF 4 NO. 14-15-00008-CV MICHAEL SLEEMAN § IN THE DISTRICT COURT AND DIANE SLEEMAN § APPELLANT § § V. § 309TH JUDICIAL DISTRICT § ESTHER CHUDLEIGH § APPELLEE § HARRIS COUNTY, TEXAS APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF Appellee, ESTHER CHUDLEIGH, asks the Court to extend the time to file its brief and respectfully shows the following: A. INTRODUCTION 1. Appellants are MICHAEL AND DIANE SLEEMAN; Appellee is ESTHER CHUDLEIGH. 2. Appellee’s brief is due on June 28, 2015. 3. Appellee respectfully requests an additional 30 days to file its brief, extending the time until July 28, 2015. 4. The parties have agreed to this motion. B. ARGUMENT & AUTHORITIES 5. Appellee's attorney Terisa Taylor of The Law Office of Terisa Taylor, P.C., needs additional time to file its brief because Appellee’s attorney has an unusually heavy docket, staff on vacation, and the research, preparation, and drafting off the Appellee's brief will be disrupted by the heavy docket and absent of the staff. E. CHUDLEIGH – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 2 OF 4 6. No extension has been granted to extend the time to file Appellee's brief. 7. Appellee's Agreed Motion to Extend Time to File Appellee's Brief is not sought for delay, but so that the interest of justice may be served. C. PRAYER 4. For these reasons, ESTHER CHUDLEIGH, asks this Court to grant an extension of time to file response to appellant’s brief. Respectfully submitted, The Law Office of Terisa Taylor, P.C. 917 Franklin Street, Suite 510 Houston, Texas 77002 Tel: (713) 224-9900 Fax: (713) 224-9903 Email: service@ttaylorlawoffice.net /s/ Terisa Taylor By: TERISA TAYLOR SBN: 24000240 GRACE M. CRUMP SBN: 24083482 Counsel for: Appellee E. CHUDLEIGH – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 3 OF 4 CERTIFICATE OF CONFERENCE I hereby certify that I have conferred with Walter P. Mahoney, Jr.’s, via telephone on June 25, 2015, and he has agreed and is unopposed to this Agreed Motion to Extend Time to File Appellee’s Brief. /s/ Terisa Taylor` TERISA TAYLOR GRACE M. CRUMP CERTIFICATE OF SERVICE I hereby certify that on the 25th day of June, 2015, a true and correct copy of the foregoing instrument was served upon each attorney of record or party in accordance with the Texas Rules of Civil Procedure. /s/ Terisa Taylor` TERISA TAYLOR GRACE M. CRUMP E. CHUDLEIGH – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 4 OF 4