ACCEPTED
01-15-00930-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/29/2015 1:55:20 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00930-CV
IN THE COURT OF APPEALS
FIRST DISTRICT OF TEXAS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS HOUSTON, TEXAS
12/29/2015 1:55:20 PM
CHRISTOPHER A. PRINE
Clerk
Harris County, Texas,
Appellant,
v.
Stephanie Jo Baker,
Appellee
________________________________________________________________
ON APPEAL FROM THE 295TH JUDICIAL DISTRICT COURT
OF HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2014-02549
APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME
_________________________________________________________________
Tritico Rainey, P.L.L.C.
L. JAMES KRELL
State Bar No. 24072191
RON S. RAINEY
State Bar No. 16484425
1523 Yale Street
Houston, Texas 77008
(713) 581-3399
(713) 581-3360 (Facsimile)
ATTORNEYS FOR APPELLEE
1
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, STEPHANIE JO BAKER, Appellee herein, by and through
their undersigned counsel, and files this Appellees’ Unopposed Motion for
Extension of Time to File her Appellee’ Brief in compliance with Rules 38.6(d)
and 10.5 of the Texas Rules of Appellate Procedure. In support of this motion,
Appellant would show as follows:
(a) After receiving an extension, Appellants’ brief was filed on December
16, 2015.
(b) Appellee requests an extension of fourteen (14) days, until January 18,
2016 to prepare her brief.
(d) This is Appellee’s first request and/or motion for an extension of time.
(e) Appellee is requesting this extension so that she might adequately
brief the issues in dispute in this case, and it is not sought for the
purpose of an improper delay.
(f) the undersigned has conferred with counsel for the Appellant, and the
Appellant is unopposed to this motion.
Appellants allege good cause exists for this request due to the undersigned’s
litigation and appellate schedule. The undersigned is currently assisting in both
criminal and civil matters at the trial and appellate level for his firm, Tritico
Rainey, PLLC. Moreover, while assisting in the drafting and preparation of these
appeals, the undersigned is also maintaining a litigation practice throughout the
state of Texas
2
WHEREFORE, PREMISES CONSIDERED, Appellants respectfully
request that this Honorable court grant an extension of fourteen (14) days, up to
and including, Monday, January 18, 2016, to file Appellee’s brief.
Respectfully submitted,
TRITICO RAINEY, PLLC
By: /s/ L. James Krell
L. JAMES KRELL
State Bar No. 24072191
RON S. RAINEY
State Bar No. 16484425
1523 Yale Street
Houston, Texas 77008
(713) 581-3399
(713) 581-3360 (Facsimile)
ATTORNEYS FOR
APPELLEE
3
CERTIFICATE OF CONFERENCE
I hereby certify that on December 29, 2015, I conferred with Keith Toler,
counsel for Appellant, by email regarding this motion. He indicated to me that he
was unopposed to this motion,
/s/ L. James Krell
L. James Krell
CERTIFICATE OF SERVICE
Pursuant to Rule 9.5(b)(1) of the Texas rules of Appellate Procedure, I do
hereby certify that if the email address for counsel of record for the Appellee is on
file with the electronic filing manager, then a true and correct copy of the
foregoing pleading was served electronically through the electronic filing manager.
In addition, I do hereby certify that a true and correct copy of the foregoing
pleading was served by facsimile to Mr. Keith Toler, on the 29th day of December,
2015.
/s/ L. James Krell
L. James Krell
4
Harris County, Texas v. Stephanie Jo Baker
Combined Opinion