Guam Industrial Services, Inc. D/B/A Guam Shipyard v. Dresser-Rand Company ( 2015 )

ACCEPTED
01-15-00842-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/12/2015 2:55:45 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00842-CV
FILED IN
IN THE COURT OF APPEALS FOR THE 1st COURT OF APPEALS
HOUSTON, TEXAS
FIRST DISTRICT OF TEXAS
11/12/2015 2:55:45 PM
CHRISTOPHER A. PRINE
Clerk
GUAM INDUSTRIAL SERVICES, INC.,
Appellant,
v.
DRESSER-RAND COMPANY,
Appellee.
ON APPEAL FROM THE 61ST JUDICIAL DISTRICT COURT
HARRIS COUNTY, TEXAS
TRIAL CAUSE NO. 2015-01910
UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
THE DIETRICH LAW FIRM
Fred Dietrich
State Bar 05857050
2211 Norfolk St., Suite 620
Houston, Texas 77098
Tel.: 713.830.7687
Fax: 713.893.6044
fdietrich@dietrich-law.com
ATTORNEY FOR APPELLANT
GUAM INDUSTRIAL SERVICES, INC.
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TO THE HONORABLE FIRST COURT OF APPEALS:
Pursuant to Tex. R. App. P. 10.5(b), appellant Guam Industrial Services, Inc. moves
for an order extending the November 24, 2015 due date for its appellant’s brief to and
including December 23, 2015 (a 29 day extension). In support of its motion, appellant
respectfully offers the following:
1. Appellant’s brief is due on November 24, 2015.
2. Appellant seeks a 29 day extension.
3. The requested extension of time is needed because appellant’s attorney’s
schedule, family obligations, and time commitment to other cases has
prevented him from focusing on preparing appellant’s brief, appellant’s
attorney will soon be requesting supplementation of the Clerk’s Record, and
the additional time is needed to give appellant’s attorney adequate time to
prepare appellant’s brief.
4. Appellant Guam Industrial Services, Inc. has not previously sought any other
extensions nor has any extension been granted to appellant.
5. Counsel for Appellee Dresser-Rand Company does not oppose this motion.
Therefore, appellant Guam Industrial Services, Inc. requests an order allowing it to
file its appellant’s brief on or before December 23, 2015.
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Respectfully submitted,
THE DIETRICH LAW FIRM
/s/ Fred Dietrich
By:
Fred Dietrich
State Bar 05857050
2211 Norfolk St., Suite 620
Houston, Texas 77098
Tel.: 713.830.7687
Fax: 713.893.6044
fdietrich@dietrich-law.com
ATTORNEY FOR APPELLANT
GUAM INDUSTRIAL SERVICES, INC.
CERTIFICATE OF CONFERENCE
On November 12, 2015, I spoke with Mr. Kyle Reeb, attorney for appellee, about this
motion and the extension requested, and Mr. Reeb informed me that appellee does not
oppose this motion.
/s/ Fred Dietrich
Fred Dietrich
CERTIFICATE OF SERVICE
I certify that a true and correct copy of this Unopposed Motion for Extension of Time
to File Appellant’s Brief was served on the following by e-service November 12, 2015:
Mr. Kyle C. Reeb
PORTER HEDGES, LLP
ATTORNEY FOR PLAINTIFF-APPELLEE
DRESSER-RAND COMPANY
/s/ Fred Dietrich
Fred Dietrich
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