Country Title , L.L.C. v. Morenike Jaiyeoba ( 2015 )


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  •                                                                                              ACCEPTED
    01-14-00931-cv
    FIRST COURT OF APPEALS
    HOUSTON, TEXAS
    4/1/2015 12:26:32 PM
    CHRISTOPHER PRINE
    CLERK
    01-14-00931-CV
    FILED IN
    1st COURT OF APPEALS
    IN THE COURT OF APPEALS                  HOUSTON, TEXAS
    4/1/2015 12:26:32 PM
    FOR THE FIRST DISTRICT OF TEXAS         CHRISTOPHER A. PRINE
    HOUSTON, TEXAS                           Clerk
    COUNTRY TITLE, L.L.C.
    Appellant
    v.
    MORENIKE JAIYEOBA
    Appellee.
    APPELLANT’S FIRST MOTION TO EXTEND TIME
    TO FILE APPELLANT’S BRIEF
    TO THE HONORABLE COURT OF APPEALS,
    Appellant, Country Title L.L.C. (“Country Title”) file this First Motion to
    Extend Time to File Appellant’s Brief pursuant to Texas Rule of Appellate
    Procedure 10 in support thereof would show the following circumstances warrant
    an extension:
    The reporter’s record in this case was filed on March 9, 2015 and the
    appellate record is not complete. Accordingly, Appellees’ deadline for filing its
    Appellant’s Brief is currently Wednesday, April 8, 2015.
    1
    02929.825 / 1733983.1
    Appellant seeks a thirty (30) day extension of time in which to file its
    Appellant’s Brief, such that its brief is due on Friday, May 8, 2015.
    This request for extension of time is not sought to cause delay or prejudice,
    but only so that justice may be done. Appellant’s counsel has had scheduling
    conflicts throughout the month of March with deadlines which interfere with the
    current deadline. Specifically, Jim McConn, lead counsel for Country Title, has
    the scheduling conflicts:
    03/13/2015         Docket Call/Pre-Trial Conference
    Cause No. 14-01-01117-CV
    Robert Ling v. Andrew Musgrove v. Grand Harbor
    Property Owners Association
    284th Judicial District Court of Montgomery County,
    Texas
    03/13/2015         Preliminary Hearing Conference
    AAA NO. 01-14-0001-8183
    LAS Properties, et al v. Pinnacle Ridge GP, LLC, et al
    American Arbitration Association
    03/16/2015         Non-Jury Trial
    Cause No. 14-01-01117-CV
    Robert Ling v. Andrew Musgrove v. Grand Harbor
    Property Owner Association
    284th Judicial District Court of Montgomery County,
    Texas
    03/16/2015         Motions for Summary Judgment Hearing
    Cause No. 2014-10063
    Azim Keramati, et al vs. Planned Community
    Management, Inc., Fall Creek Homeowners Association,
    Inc., Severn Trent Services, Inc. and The Johnson
    Development Corp.
    281st Judicial District Court of Harris County, Texas
    2
    02929.825 / 1733983.1
    03/17/2015        Motion to Compel Discovery Responses/Motion for
    Protection
    Cause No. 14-0177
    Springlake Property Owners’ Association, Inc. v. Gerald,
    Kirk and Amy Kirk
    22nd Judicial District Court of Hays County, Texas
    03/20/2015        Appellees’ Brief due
    Cause No. 01-14-00216-CV
    Victor Elgohary v. Lakes on North Eldridge Community
    Association, Inc. et al.
    Court of Appeals for the First Judicial District, Houston,
    TX
    03/30/2015        Motion to Enforce Mediation Settlement Agreement
    Cause No. 2012-50554
    Jean M. Robingston, Nelida Cerna and Maricela Garcia
    v. Dilston House Condominium Association and Genesis
    Management Company, Inc.
    234th Judicial District Court of Harris County, Texas
    03/30/2015        Motion for Protection
    Cause No. 2014-71936
    Taylor Morrison of Texas, Inc. v.
    Stewart, Tamesha Stewart and Greater Emmanuel
    Apostolic Church v. Advantage Title of Ft. Bend, L.C.
    and Raymond C. Kerr in his Capacity as Arbitrator
    152nd District Court of Harris County, Texas
    These deadlines represent some of the conflicts presently on Appellant’s
    counsel’s calendar and do not include depositions, discovery, and other ongoing
    case and client obligations.
    3
    02929.825 / 1733983.1
    PRAYER
    WHEREFORE PREMISES CONSIDERED, Appellant respectfully requests
    that this Honorable Court grant it an extension of thirty (30) days to file its
    Appellant’s Brief so that its deadline will be Friday, May 8, 2015, and for any such
    further relief to which it may be entitled.
    Respectfully submitted,
    LeClairRyan
    /s/ James J. McConn, Jr.
    By:_________________________
    James J. McConn, Jr.
    Email: james.mcconn@leclairryan.com
    1233 West Loop South, Suite 1000
    Houston, Texas 77027
    Telephone: 713-654-1111
    Facsimile: 713-650-0027
    ATTORNEY FOR APPELLANT
    CERTIFICATE OF SERVICE
    As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), (e), I certify
    that I have served this document on all other parties which are listed below on
    April 1, 2015 as follows:
    Teltschik-Grubbs, PLLC
    Corwin L. Teltschik
    Betsy Grubbs
    14015 Southwest Freeway, Suite 4
    Sugar Land Texas 77478
    Fax: 281-201-1202                                  /s/ James J. McConn, Jr.
    _________________________
    James J. McConn, Jr.
    4
    02929.825 / 1733983.1
    CERTIFICATE OF CONFERENCE
    As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I
    contacted Appellee’s counsel on March 30, 2015 by email. Appellee’s counsel
    indicated they are unopposed to Appellant’s First Motion to Extend Time to File
    Appellant’s Brief.
    /s/ James J. McConn, Jr.
    _________________________
    James J. McConn, Jr.
    5
    02929.825 / 1733983.1
    

Document Info

Docket Number: 01-14-00931-CV

Filed Date: 4/1/2015

Precedential Status: Precedential

Modified Date: 9/29/2016