Christine Reule v. John R. Belus

ACCEPTED 14-15-00190-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/21/2015 7:12:53 PM CHRISTOPHER PRINE CLERK No. 14-15-00190-CV FILED IN IN THE COURT OF APPEALS 14th COURT OF APPEALS HOUSTON, TEXAS FOR THE FOURTEEN DISTRICT OF TEXAS 10/21/2015 7:12:53 PM HOUSTON, TEXAS CHRISTOPHER A. PRINE Clerk CHRISTINE E. REULE, Appellant v. JOHN R. BELUS Appellee __________________________________________________________________ On Appeal from Cause No. 2014-37325 190 Judicial District Court of Harris County, Texas TH __________________________________________________________________ APPELLANT’S MOTION FOR AN EXTENSION OF TIME IN WHICH TO FILE THE BRIEF --------------------------------------------------------------------------------------------------------------------- CHRISTINE E. REULE Pro Se 1831 Sherwood Forest #24 Houston, Texas 77043 (713) 365-0535 IDENTITY OF PARTIES AND THEIR COUNSEL Appellant, Christine E. Reule, hereby certifies that the following are the list of parties and their respective counsel, if any, to the best of her knowledge and understanding of the rules. PARTIES COUNSEL Appellant CHRISTINE E. REULE Pro Se 1831 Sherwood Forest #24 Houston, Texas 77043 (713) 365-0535 Creule@msn.com Appellee JOHN R. BELUS D. John Neese 2118 Smith Street Houston, Texas 77002 jneese@hmgnc.com KELLY SANCHEZ AND VALLOUREC Jeffrey D. Burbach DRILLING PRODUCTS USA, INC Jackson Walker L.L.P. 1401 McKinney, Suite 1900 Houston, Texas 77010 713.752.4262 (direct) jburbach@jw.com WENDY HATZ AND DURA BOND PIPE COREY REED Thompson Coe Cousins & Irons, L.L.P One Riverway, Suite 1400 Houston, Texas 77056 Phone: 713-403-8213 creed@thompsoncoe.com TO THE HONORABLE COURT OF APPEALS OF TEXAS: Christine E. Reule, Appellant, and those similarly situated, respectfully submits this motion for extension of time in which to file her brief. This court previously sustained Appellant’s objection to the prior deadline in accordance with T.R.A.P. 38.6, Appellant’s brief is due thirty (30) days after the later of: “(1) the date the clerk’s record was filed; and (2) th date the reporter’s record was filed.” There were many missing records, and transcripts. The court set the new deadline for October 21, 2015. As the court may recall, Appellant has numerous medical issues, and has treated with a new doctor, who confirmed her diagnosis. Stress severely aggravates Appellant’s medical condition. Her hands are swollen, she’s extremely fatigue making it difficult to concentrate, type and she’s in severe pain. Appellant contacted Appellees to see if any had an objection on October 21, 2015. Neither Jeffrey Burbach or D. John Neese, Jr. bother to reply. Cory Reed was the only one who was opposed. Good cause exists for the extension which is not sought for purpose of delay. The extension is an accommodation for Appellant’s disability and medical conditions. Therefore, appellant requests that this court grant her a 30 day extension from the date of the order, due to her disability and medical condition. PRAYER For these reasons, Appellant requests that this court grant her a 30 day extension of time in which to file her brief, and for such other and further relief as the court deems just and proper. Dated: October 21, 2015 Respectfully submitted, /s/Christine Reule ________________________________ Christine E. Reule 1831 Sherwood Forest #24 Houston, Texas 77043 Creule@msn.com CERTIFICATE OF MAILING The above and foregoing document was served in accordance with Rule 21a on this 21st day of October 2015, on all interested parties in this case.