Patricia Gonzalez v. Nestor Villafana and Ramon Walle

ACCEPTED 14-15-00328-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/28/2015 2:38:03 PM CHRISTOPHER PRINE CLERK NO. 14-15-00328-CV PATRICIA GONZALEZ § IN THE FOURTEENTH FILED IN 14th COURT OF APPEALS APPELLANT, § HOUSTON, TEXAS § 10/28/2015 2:38:03 PM VS. § COURT OFCHRISTOPHER APPEALS A. PRINE Clerk § RAMON WALLE § APPELLEE. § HOUSTON, TEXAS APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE THE BRIEF Appellee, Ramon Walle, asks the Court to extend the time to file the Appellee brief. A. Introduction 1. Appellant is Patricia Gonzalez; appellee is Ramon Walle. 2. No rule provides a deadline to file this motion to extend. See TEX. R. APP. P. 38.6(d). 3. The Appellant is agreed to this motion. B. Argument & Authorities 4. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time to file the brief. 5. Appellee’s brief is due on October 28, 2015. 6. Appellee requests an additional 1 week to file his brief, extending the time until November 4, 2015. 7. This is the second request for an extension to file the Appellee’s Brief. 8. Appellee needs additional time to complete research and complete drafting the brief. C. Prayer 9. For these reasons, Appellee asks the Court to grant an extension of time to file her brief until November 4, 2015. Respectfully submitted, THE ANDERSON FIRM, LLC KATHRYN P. ANDERSON Texas Bar No. 24032829 5629 Cypress Creek Parkway Suite 216 Houston, Texas 77069 Telephone: 281-895-9800 Facsimile: 281-895-9801 Attorney for Appellee Ramon Walle 2 CERTIFICATE OF CONFERENCE I certify I have conferred with opposing counsel by email, and he is agreed to the Motion to Extend Time to File the Brief. Kathryn P. Anderson CERTIFICATE OF SERVICE I certify that a copy of Appellant’s Motion to Extend Time to File the Brief was served on Appellant, Patricia Gonzalez, through her counsel of record listed below by e-service on October 28, 2015: Jack Todd Ivey & Jacob D. Barber Ivey Law Firm, P.C. One Katy Plaza 11111 Katy Freeway, Suite 580 Houston, TX 77079 Counsel for Appellant Kathryn P. Anderson 3