ACCEPTED
14-14-00829-cv
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/6/2015 3:09:04 PM
CHRISTOPHER PRINE
CLERK
No. 14-14-00829-CV
FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURT OF APPEALS FOR THE
7/6/2015 3:09:04 PM
CHRISTOPHER A. PRINE
FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS Clerk
HOUSTON, TEXAS
MICHAEL QUEEN and IAN MAGEE,
Appellants/Cross Appellees,
v.
RBG USA, Inc.,
Appellee/Cross Appellant.
On appeal from the
268th Judicial District Court of Fort Bend County, Texas
JOINT MOTION FOR EXTENSION OF TIME
TO FILE RESPONSIVE AND REPLY BRIEFS
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
Appellants Michael Queen and Ian Magee (collectively, “Appellants”) and
Appellee RBG USA, Inc. (“Appellee”) (Appellants and Appellee are collectively
referred to as the “Parties”), in the above-styled and numbered cause, file this Joint
Motion for Extension of Time to File Responsive and Reply Briefs and request that
the Court enter an order extending the time for the filing of their Responsive Briefs
with the Court through, and including June 15, 2015, and for the filing of their
Reply Briefs, if any, with the Court through, and including August 4, 2015, and in
support thereof would respectfully show the following:
1. The Parties’ current deadline to file their Responsive Briefs is July 8,
2015.
2. The Parties’ current deadline to file their Reply Briefs, if any, is July
28, 2015.
3. The Parties’ counsels need additional time to prepare their Responsive
and Reply Briefs because of their professional and personal schedules.
4. This is the Parties’ first request for an extension of time to file their
Responsive and Reply Briefs. This motion is not sought for delay but so that
justice may be done.
WHEREFORE, PREMISES CONSIDERED, the Parties respectfully pray
that the Court grant their Joint Motion for Extension of Time to File Responsive
and Reply Briefs and extend the time for them to file their Responsive Briefs
through, and including, July 15, 2015, and extend the time for them to their Reply
Briefs, if any, through, and including August 4, 2015.
[signatures on following page]
Respectfully submitted,
/s/ Stephen J. Schechter1 /s/ Michael R. Rahmn
Stephen J. Schechter Craig D. Dillard
State Bar No. 17735512 State Bar No. 24040808
STEPHEN J. SCHECHTER, P.C. Michael R. Rahmn
P.O. Box 792 State Bar No. 24074924
Boerne, Texas 78006 GARDERE WYNNE SEWELL LLP
Telephone: (830) 249-3500 1000 Louisiana, Suite 3400
Facsimile: (830) 249-8500 Houston, Texas 77002-5007
stephen@sjs-pc-law.com Telephone: (713) 276-5500
Facsimile: (713) 276-5555
ATTORNEY-IN-CHARGE FOR cdillard@gardere.com
APPELLANTS MICHAEL QUEEN mrahmn@gardere.com
AND IAN MAGEE
ATTORNEYS FOR
APPELLEE RBG USA, INC.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Joint Motion for
Extension of Time to File Briefs has been served on Appellants’ attorney of record
on July 6, 2015.
/s/ Michael R. Rahmn
Michael R. Rahmn
1
With permission
6777000v.1