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

ACCEPTED 01-15-00661-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 11/12/2015 11:35:19 PM CHRISTOPHER PRINE CLERK 01-15-00661-CV FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE COURT OF APPEALS 11/12/2015 11:35:19 PM FOR THE CHRISTOPHER A. PRINE FIRST DISTRICT OF TEXS AT HOUSTON Clerk PATRICK O'CONNOR & ASSOCIATES, LP Appellant v. CHESTER R. HALL Appellee THIRD 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, files this Unopposed Second Motion to Extend Time to File Appellant's Brief. Appellant's opening brief is currently due on November 12, 2015. Counsel for Appellant requests a 10-day extension of time to file its brief, making the brief due on November 22, 20 15. This is the third 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 experienced unforeseen technical difficulties that prevented him from fin~lizing and filing Appellate Brief on the date due. Due to the unforeseeable nature of this occurrence, Counsel for Appellant was unable to confer with Appellee's Counsel to obtain permission for the extention. 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. 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, Saif A. Siddiqui The Siddiqui Law Firm Texas Bar No. 24052305 3345 E. T. C. Jester, Suite F-11 Houston, TX 77018 ss@siddiquilaw .com Tel. (713) 927-2775 Fax. (713) 457-2961 Tel. (713) 927-2775 Fax. (713) 457-2961 ATTORNEY FOR APPELLANT 3 CERTIFICATE OF SERVICE I hereby certify Pursuant to Rule 21a that on this the 12nd day ofNovember, 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