Joan DeYoung, Stephen DeYoung, M.D., and David DeYoung v. William L. Maynard, Individually and as of the Estate of Judy Page Maynard, and Maynard Properties, L.P.

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ACCEPTED 01-15-00260-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 11/18/2015 11:21:28 AM CHRISTOPHER PRINE NO. 01-15-00260-CV CLERK IN THE COURT OF APPEALS FOR THE 1ST JUDICIAL DISTRICT OF TEXAS AT HOUSTON FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/18/2015 11:21:28 AM CHRISTOPHER A. PRINE JOAN DEYOUNG, STEPHEN DEYOUNG, M.D, AND DAVID DEYOUNG, Clerk Appellants, V. Judy Page Maynard, William L. Maynard, Maynard Properties, L.P., Appellees. FROM THE 270TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE BRIEF LAW OFFICE OF GREGORY N. JONES By: /s/ Gregory N. Jones SBN 10889450 2323 S. Shepherd, 14th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax Counsel for Appellees As pointed out in Appellee’s last request for extension, Appellees’ counsel has health issues having incurred several seizures. As a result of various prescribed medications, counsel has been unable to completely function, including driving until mid-December 2015. When coupled with the Thanksgiving and Christmas holiday seasons , Appellees therefore respectfully request an extension of sixty (60) days to file their response brief in this appeal. BACKGROUND FACTS 1. On March 19, 2015, the DeYoungs filed their notice of appeal. The clerkʼs record was filed on June 16, 2015, the Appellants’ brief was filed on August 17, 2015, which means that Appellees’ brief was due September 17, 2105. This date was extended to November 19, 2015, as a result of Appellees’ previous unopposed request for extension. 2. Appellees’ counsel’s health condition has prevented Appellees’ counsel from devoting the necessary time and attention to their response brief. 2 PRAYER / RELIEF REQUESTED For the foregoing reasons, Appellees request an extension of at least 30- day the deadline to file their brief, or until January19, 2016. Respectfully submitted, LAW OFFICE OF GREGORY N. JONES /s/ Gregory N. Jones Gregory N. Jones 2323 S. Shepherd, 14th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax gjones@gnjlaw.net Counsel for Appellees CERTIFICATE OF CONFERENCE I certify to the Court that I have conferred with appellees’ counsel who indicated that appellees are opposed to the relief sought by this motion. /s/ Gregory N. Jones Gregory N. Jones 3 CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. P. 9.4(i), I certify to the Court that the foregoing document contains 441 words. In calculating the word count, I relied on the “Word Count” function of the computer program used to generate this document. /s/ Gregory N. Jones Gregory N. Jones CERTIFICATE OF SERVICE I certify that a copy of the foregoing document has been electronically served on all counsel of record on November 18th, 2015: /s/ Gregory N. Jones Gregory N. Jones Daniel W. Jackson, SBN 00796817 William L. Maynard Scott K. Vastine, SBN 24056469 1300 Post Oak Blvd. Ste. 2500 3900 Essex Lane, Suite 1116 Houston, Texas 77056 Houston, Texas 77027 Fax: (713) 960-1527 (713) 527-8850 – fax daniel@jacksonlaw-tx.com scott@jacksonlaw-tx.com 4