in the Matter of the Marriage of Lorena Aldana and Jose Aldana ( 2015 )


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  •                                                                                                         ACCEPTED
    14-15-00741-cv
    FOURTEENTH COURT OF APPEALS
    HOUSTON, TEXAS
    9/21/2015 7:35:45 PM
    CHRISTOPHER PRINE
    CLERK
    NO. 14-00741-CV
    __________________________________________
    FILED IN
    14th COURT OF APPEALS
    HOUSTON, TEXAS
    COURT OF APPEALS FOR THE FOURTEENTH                              9/21/2015 7:35:45 PM
    CHRISTOPHER A. PRINE
    DISTRICT OF TEXAS                                               Clerk
    HOUSTON, TEXAS
    __________________________________________
    IN THE MATTER OF THE MARRIAGE OF LORENA ALDANA AND JOSE
    ALDANA
    ___________________________________________
    ON APPEAL FROM ORDERS OF THE 312TH DISTRICT COURT
    HARRIS COUNTY, TEXAS
    APPELLANT’S MOTION FOR EXTENSION OF TIME TO PAY FOR COURT
    REPORTER’S RECORD
    TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
    Appellant, Jose Aldana (“Aldana”), by and through his attorney of record and files this,
    his Motion for Extension of Time to Pay for Court Reporter’s Record. In support thereof, Aldana
    would respectfully show this Honorable Court as follows:
    I.
    Appellant, Aldana respectfully requests the Court to extend the deadline for Motion for
    Extension of Time to Pay for Court Reporter’s Record from January 21, 2015 to March 01, 2014
    or thirty days after this Court enters an order on Appellant’s Motion to Dismiss and Motion to
    Strike Appellants’ Brief. Under the TEX. R. APP. P. 10.5(b), Appellant would respectfully show
    1
    as follows:
    1.     The deadline for filing the Appellant’s Motion for Extension of Time to Pay for
    Court Reporter’s Record is September 21, 2015.
    2.     Appellant seeks an extension of time to pay for Court Reporter’s Record to October
    30, 2015 or thirty days after the 312th District Court in Harris County enters an order
    on Appellant’s Motion Reconsideration.
    3.     The following facts were reasonably relied upon for the need of an extension to pay
    for Court Reporter’s Record and are stated with personal knowledge of the
    undersigned counsel:
    a. Appellant, Jose Aldana, has filed with the 312th District Court in Harris
    County on August 28, 2015 a Motion for Reconsideration, which has not yet
    been ruled on or heard.    Furthermore, Appellant’s have a hearing set on this
    Motion for Reconsideration on September 23, 2015 at 09:00 a.m. Therefore,
    since hearings, rulings, and orders are still pending in the lower court,
    Appellant requests an extension of time to pay for the court reporter’s record.
    4.     No previous extensions have either been filed or granted in this case by Appellant.
    5.     This request is not made for undue delay but only so that justice may be served.
    6.     The undersigned counsel does not believe the Appellee will oppose this motion.
    II.
    Appellant requests that this Honorable Court grant Appellant’s Motion to Extend Time to
    File Appellant’s Brief from September 21, 2015 to October 30, 2015 or thirty days from when
    the 312th District Court in Harris County Court enters an order on Appellant’s Motion for
    Reconsideration.
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    PRAYER
    WHEREFORE, PREMISES CONSIDERED, Appellant, Jose Aldana, requests that
    this Court grant Appellant’s Motion to Extend Time to Pay for Court Reporter’s Record.
    Respectfully submitted,
    LUNA & ASSOCIATES
    By:        /s/ Briseida M. Luna     ____________
    Briseida M. Luna
    Texas Bar No. 24070184
    2425 West Loop South
    Suite 200
    Houston, Texas 77027
    Tel. (713) 364-6510
    Fax. (713) 581-1016
    bluna@lunalawassociates.com
    ATTORNEYS FOR APPELLANT/
    JOSE ALDANA
    CERTIFICATE OF CONFERENCE
    As required by the Texas Rules of Appellate Procedure 10.1(a)(5), I certify that on
    September 18, 2015, I made a reasonable attempt to confer, with all parties listed below about
    the merits of this motion with the following results:
    Mr. Carl Selesky, Attorney for Appellee
    Opposes motion
    Does not oppose motion
    Agrees with motion
    Would not say whether motion is opposed
    3
    X          Did not return my message regarding the motion
    /s/ Briseida M. Luna
    Briseida M. Luna
    ATTORNEY FOR APPELLANT
    September 21, 2015
    CERTIFICATE OF SERVICE
    As required by the Texas Rules of Appellate Procedure 6.3 and 9.5(b), (d), (e) I certify
    that a true and correct copy of this document was on all attorneys and parties of record on this
    the 21st day of September 2015 which are listed below as follows:
    SELESKY
    LAW
    FIRM
    Carl
    Selesky
    5225
    Katy
    Freeway,
    Ste.
    605
    Houston,
    Texas
    77007
    713-­‐782-­‐5226
    (Fax)
    Attorney for Appellee, Lorena Aldana
    /s/ Briseida M. Luna
    Briseida M. Luna
    ATTORNEY FOR APPELLANT
    September 21, 2015
    4
    

Document Info

Docket Number: 14-15-00741-CV

Filed Date: 9/21/2015

Precedential Status: Precedential

Modified Date: 9/30/2016