Debbie Pattillo v. Sylvia Franco ( 2015 )

ACCEPTED
14-15-00628-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/21/2015 3:16:46 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00628-CV
__________________________________________
IN THE COURT OF APPEALS FOR THE FILED IN
FOURTEENTH DISTRICT OF TEXAS 14th COURT OF APPEALS
HOUSTON, TX HOUSTON, TEXAS
__________________________________________10/21/2015 3:16:46 PM
DEBBIE PATTILLO, CHRISTOPHER A. PRINE
APPELLANT, Clerk
V.
SYLVIA FRANCO,
APPELLEE.
___________________________________________________________
On Appeal from Cause No. 1024502
County Court at Law No. 4, Harris County, Texas
Honorable Roberta Lloyd, Presiding Judge
_____________________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
_____________________________________________________________________________
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS:
Appellant, Debbie Pattillo, files this Unopposed Motion for Extension of Time to File
Appellant’s Brief and in support shows the following:
1. Appellant’s Brief is due on October 22, 2015. Appellant requests an extension time of
thirty days, to November 20, 2015 to file its Brief.
2. Appellant relies on the following facts as a reasonable explanation for the requested
extension of time: The trial transcript was filed on 9/22/2015 but Appellant did not
receive the trial transcript until October 13, 2015. Additionally, Appellant’s counsel
was called for jury duty and has not had time to finsh the brief by the filing deadline
of 10/22/2015. The extension is not sought for the purpose of delay.
3. The undersigned has conferred with opposing counsel, Kelli Smith who indicated
there was no opposition to this request.
WHEREFORE, ABOVE PREMISES CONSIDERED, Appellant DEBBIE
PATTILLO, respectfully prays that this Honorable Court grant this motion for extension of time.
APPELLANT'S MOTION FOR EXTENSION PAGE 1 OF 2
Respectfully submitted,
BAILEY & GALYEN
4131 N. Central Expressway, Suite 860
Dallas, TX 75204
(214) 252-9099 - Office
(214) 520-9941 – Facsimile
srobelen@galyen.com- Email
By: ___/s/ Scott G. Robelen .
Scott G. Robelen
Texas State Bar No.: 16990045
Federal Bar No.: 870867
ATTORNEY FOR PLAINTIFF
CERTIFICATE OF CONFERENCE
I certify that my assistant conferred with Kelli Smith on October 21, 2015 who indicated
that this motion is unopposed.
___/s/ Scott G. Robelen .
Scott G. Robelen
CERTIFICATE OF SERVICE
I certify that on 21st day of October, 2015, I served a copy of this motion by Facsimile at
(713) 739-7420 and ECF to : Kelli Smith and Barbara Hachenburg who are the attorneys in
charge for Appellee, SYLVIA FRANCO APPELLEE, and whose address is GERMER PLLC,
Three Allen Center, 333 Clay Street, Suite 4950, Houston, TX 77002, (713) 650-1313
Telephone and (713) 739-7420 Facsimile
___/s/ Scott G. Robelen .
Scott G. Robelen
APPELLANT'S MOTION FOR EXTENSION PAGE 2 OF 2