Patrick O'Connor & Associates, LP v. Chester R. Hall

ACCEPTED 01-15-00661-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 11/2/2015 3:11:56 PM CHRISTOPHER PRINE CLERK 01-15-00661-CV FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE COURT OF APPEALS 11/2/2015 3:11:56 PM CHRISTOPHER A. PRINE FOR THE FIRST DISTRICT OF TEXS AT HOUSTON Clerk PATRICK O'CONNOR & ASSOCIATES, L.P. Appellant v. CHESTER R. HALL Appellee FIRST UNOPPOSED MOTION FOR EXTENTISION OF TIME TO FILE APPELLANT'S BRIEF Appeal from Cause No. 1036533, In the County Court at Law No. 4, Harris County, Texas THE LAW OFFICES OF VEKENO KENNEDY THE SIDDIQUI LAW FIRM Vekeno Kennedy Saif A. Siddiqui Texas Bar No. 24077118 Texas Bar No. 24052305 3346 E. T.C. Jester Blvd., Suite F-27 3346 E. T.C. Jester, Suite F-11 Houston, Texas 77018 Houston, Texas 77018 Phone:(713) 375-4230 Tel: (713) 927-2775 Fax: (713) 457-2954 Fax: (832) 787-1284 kennedy.re.law@gmail.com ss@siddiquilaw.com ATTORNEYS FOR APPELLANT 1 TO THE HONORABLE FOURTEENTH COURT OF APPEALS: Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant, Patrick O'Connor & Associates, L.P. files this Unopposed Second Motion to Extend Time to File Appellant's Brief. Appellant's opening brief is currently due on November 2, 2015. Counsel for Appellant requests a 10-day extension of time to file its brief, making the brief due on November 12, 2015. This is the second request for extension of time to file the opening brief. Counsel for Appellant relies on the following reasons, in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the requested extension: Counsel for Appellant was unable to obtain a copy of the reporter' s transcript with sufficient time to complete Appellant's Brief, as the Court Reporter responsible for its preparation could not be located in a timely manner. Counsel for Appellant seeks this extension of time to be able to prepare a cogent and succinct brief to aid this Court in its analysis of the issues presented. This request is not sought for delay but so that justice may be done. The undersigned has conferred with opposing counsel, and he has indicated that his client does not oppose this motion. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2. 2 PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Unopposed First Motion to Extend Time to File Appellant's Brief and extend the Deadline for Filing the Appellant's Brief up to and including November 12, 2015, and grant Appellant all other relief to which it may be entitled. Respectfully submitted, LAW OFFICE OF VEKENO KENNEDY / Vekeno Kennedy Vekeno Kennedy Texas Bar No. 24077118 3346 East T.C. Jester Blvd., Suite F-27 Houston, Texas 77018 Phone:(713) 375-4230 Fax: (713) 457-2954 kennedy.re.law@gmail.com ISa if Siddiqui Saif A. Siddiqui The Siddiqui Law Firm Texas Bar No. 24052305 3346 E. T.C. Jester, Suite F-11 Houston, Texas 77018 Tel : (713) 927-2775 Fax: (713) 457-2961 ss@siddiquilaw.com ATTORNEYS FOR APPELLANT 3 CERTIFICATE OF CONFERENCE I certifY that I conferred with counsel for Appellee regarding this motion and that Appellee is not opposed to this motion. CERTIFICATE OF SERVICE I hereby certify Pursuant to Rule 21a that on this the 2nd day of November, 2015 a true and correct copy of the foregoing was forwarded by facsimile transmission, regular mail, certified mail, return receipt requested, hand-delivery, and/or by any other method as agreed between the parties to the following: Mr. Paul Pilibosian via electronic mail Hoover Slovacek, LLP 5847 San Felipe, Suite 2200 Houston, Texas 77057 4