Sharon Lee Hanson v. Guy Robb Cowen ( 2015 )

ACCEPTED
03-14-00574-CV
3697905
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/8/2015 1:35:47 PM
JEFFREY D. KYLE
CAUSE NO. 03-14-00574-CV CLERK
SHARON LEE HANSON § THIRD DISTRICT
§ FILED IN
V. § COURT OF APPEALS OF TEXAS
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
GUY ROBB COWEN § IN AUSTIN, TEXAS1/8/2015 1:35:47 PM
JEFFREY D. KYLE
Clerk
APPELLEE'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLEE'S BRIEF WITH CERTIFICATE OF CONFERENCE
TO THE HONORABLE JUSTICES OF THIS COURT:
COMES NOW GUY ROBB COWEN, APPELLANT-MOVANT, herein and files his
Motion for Extension of Time to File Appellee's Brief, pursuant to Local Rules 47 and 52 and
Texas Rules of Appellate Procedure 10.1 and 10.5(b)(1), and in support thereof shows the
following:
I. BACKGROUND AND BASIS FOR EXTENSION
Briefly, by way of background, the undersigned counsel was served Appellant's brief on
or about December 10, 2014, making the Appellee's brief on this same day. Despite efforts to
complete the brief over the holidays, Appellee cannot meet the deadline effectively. No previous
extensions have been requested by Appellee. The undersigned counsel, aside from having a trial
practice, is currently working on a total of five (5) briefs with two (2) of those being Petitions for
Certiorari to the U.S. Supreme Court from the US Court of Appeals in the 10 th and 5th Circuits.
The undersigned counsel is a solo practitioner. Additionally, it appears that the record may need
to be supplemented with a hearing transcript that has not been provided to the Court, at this time,
and which is material and relevant to the claims raised by Appellant in her brief. The undersigned
counsel seeks a thirty (30) day extension to allow her to assure there is a complete record before
the Court and adequate time to address all matters thoroughly.
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II. GOOD CAUSE AND NOT FOR DELAY
The Motion is not filed due to Movant's actions or omissions of any kind. Moreover, the
motion is not sought for delay and is in the interest of justice and to honor this country’s
constitutional mandates to the right to effective assistance of counsel and due process.
WHEREFORE, PREMISES CONSIDERED, the undersigned counsel prays that
Appellee-Movant be granted an extension of time to file his brief in the proceeding herein.
Respectfully submitted,
By:___/s/__Marie E. Galindo_______
MARIE E. GALINDO
Attorney at Law
639 Heights Boulevard
Houston, Texas 77009
Telephone No. 713.299.1510
Facsimile No. 713.651.0776
State Bar No. 00796592
ATTORNEY FOR APPELLEE-
MOVANT
Certificate of Service
On JANUARY 8, 2015, a copy of the above-referenced pleading was sent via email to
Mr. Richard Mock, Appellant's counsel, and his assistant.
__/s/_Marie E. Galindo___________
MARIE E. GALINDO
Certificate of Conference
On this same day, the undersigned counsel's office left a message and sent an email
asking Mr. Mock about his position as to the filing of this request and explained the basis of said
request. Mr. Mock has emailed that he does not oppose said motion.
_/s/_Marie E. Galindo__________________
MARIE E. GALINDO
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