Houston Laureate Associates, LTD. v. Marolyn Russell, Joel Goffman, M.D., and Park Laureate Place Homeowners' Association

ACCEPTED
14-15-00491-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
8/26/2015 12:29:11 PM
CHRISTOPHER PRINE
CLERK

Cause No. 14-15-00491-CV
__________________________________
FILED IN
14th COURT OF APPEALS
In the Court of Appeals HOUSTON, TEXAS
8/26/2015 12:29:11 PM
for the Fourteenth District of Texas CHRISTOPHER A. PRINE
Clerk
Houston, Texas

HOUSTON LAUREATE ASSOCIATES, LTD.,

Appellant,
v.

MAROLYN RUSSELL, JOEL GOFFMAN, M.D., AND
PARK LAUREATE PLACE HOMEOWNERS’ ASSOCIATION

Appellees.

Appeal from the 11th District Court of Harris County, Texas
Cause No. 2013-34999

HOUSTON LAUREATE ASSOCIATES, LTD.’S
UNOPPOSED MOTION FOR EXTENSION OF TIME

COMES NOW Appellant Houston Laureate Associates, Ltd. and files this

Unopposed Motion for Extension of Time pursuant to Texas Rule of Appellate

Procedure 10.5(b) and in support thereof would respectfully show as follows:

1. The principal brief for Appellant is due on August 31, 2015.

2. Appellant seeks an additional 30 days to file the Brief of Appellant,

up to and including Wednesday, September 30, 2015. This is Appellant’s first

request for extension of time to file briefing.
 3. The following facts reasonably explain the need for additional time.

See TEX. R. APP. P. 10.5(b)(1)(c).

4. The Original Clerk’s Record does not conform to the items requested

by the parties. There are documents missing, documents that have degraded

images rendering them illegible, and documents that have pages missing.

Appellant has filed a Supplemental Request for Clerk’s Record asking for the

correction of these problems and anticipates that it will likely be several weeks

before the supplement can be completed and filed. Therefore, Appellant requests

this extension of time to allow the Record to be corrected so that it may be cited

properly.

5. This request is not sought for delay, but in order that justice may be

done and to allow time for preparation of helpful and complete briefs on the merits.

6. This motion is unopposed.

PRAYER
Movants ask this Court to grant an extension of 30 days, until Wednesday,

September 30, 2015, to file their Brief of Appellant.

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 Respectfully submitted,

/s/ Douglas Pritchett, Jr.
Douglas Pritchett, Jr.
State Bar No. 24007877
dpritchett@johnsontrent.com
Joshua W. Mermis
State Bar No. 24039055
jmermis@johnsontrent.com
JOHNSON, TRENT, WEST & TAYLOR, L.L.P.
919 Milam Street, Suite 1700
Houston, Texas 77002
(713) 222-2323 (Telephone)
(713) 222-2226 (Facsimile)

ATTORNEYS FOR APPELLANT
HOUSTON LAUREATE ASSOCIATES,
LTD.

CERTIFICATE OF CONFERENCE
On the 26th day of August 2015, the below-signed counsel for Appellant
contacted Barry Abrams, counsel for Appellees, and was informed that Appellees
do not oppose the relief requested in this motion.

/s/ Douglas Pritchett, Jr.
Douglas Pritchett, Jr.

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 CERTIFICATE OF SERVICE
On this the 26th day of August 2015, the foregoing Unopposed Motion for
Extension of Time was served on the following persons by electronic service:
Hartley Hampton
Hampton & King
Three Riverway, Suite 910
Houston, TX 77056
hhampton@hhampton-law.com
Attorney for Park Laureate Place Homeowners Ass’n,
and for Marolyn Russell

Thomas R. McDade
Beck Redden, LLP
One Houston Center
1221 McKinney, Suite 4500
Houston, TX 77010
tmcdade@beckredden.com
Attorney for Park Laureate Place Homeowners Ass’n,
Joel Goffman, and for Marolyn Russell

Barry Abrams
Blank Rome, LLP
700 Louisiana, Suite 4000
Houston, Texas 77002
babrams@blankrome.com

Gerald M. Birnberg
Williams, Birnberg & Andersen, L.L.P.
2000 Bering, Suite 909
Houston, Texas 77057
birnberg@wba-law.com
Attorneys for Park Laureate Place Homeowners Ass’n,

/s/ Douglas Pritchett, Jr.
Douglas Pritchett, Jr.
464808

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