Harpinder Singh, Jagjit S. Gill, and Baldev Singh v. Gurnam Singh Sandhar, Inqlabi Thandi, Daljit Singh, Baljinder Singh Bhatti, Sodagar Singh Virk, and Baljinder Singh ( 2015 )

ACCEPTED
14-15-00087-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/2/2015 10:58:58 AM
CHRISTOPHER PRINE
CLERK
No. 14-115-00087-CV
FILED IN
14th COURT OF APPEALS
In the Court of Appeals for the HOUSTON, TEXAS
Fourteenth District of Texas at Houston 7/2/2015 10:58:58 AM
CHRISTOPHER A. PRINE
Clerk
HARPINDER SINGH, ET AL.
Appellant
V.
GURNAM SINGH SANDHAR ET AL.
Appellee
On Appeal from the 55th Judicial District Court
Harris County, Texas
Trial Court Case No. 2013-51397
APPELLANT’S MOTION FOR AN EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF ON THE MERITS
To the Honorable Fourteenth Court of Appeals:
1. Appellants’, Harpinder Singh, et al., respectfully file this
motion for a thirty (45) day extension of time to file the Clerk’s record and
in support respectfully state as follows:
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2. The brief of Appellants is due on July 6, 2015. This is
Appellants’ first request for an extension of time to file their brief.
3. Appellants are requesting 45 days from the granting of this
Motion in which to file their Appellant’s Brief on the Merits.
4. The counsel for Appellant is unable to confer with all
Appellees, as they are individuals unrepresented by counsel, and the
undersigned does not have a telephone number for each Appellee.
5. Counsel for the Appellant seeks this extension of time because
the Reporter’s record was just filed on June 3, 2015. Since that time,
Appellant’s counsel, Kristen Coleman, has had multiple evidentiary hearings
which have required significant time to prepare. Ms. Coleman also went on a
three day vacation. Ms. Coleman seeks additional time to prepare the
Appellant’s brief.
6. It is for these reasons that counsel for Appellant has been
unable to complete the Brief on the Merits and is requesting an extension of
time. The undersigned attorney understands the importance of deadlines and
is not requesting this extension for reasons of delay only, but that justice
may be done.
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WHEREFORE, PREMISES CONSIDERED, the Appellant
respectfully requests the Court to extend the time for filing her Brief on the
Merits in this cause by 30 days from the date of the Court’s granting of this
Motion.
Respectfully submitted,
WOODFILL LAW FIRM, PC
/s/ Kristen Coleman____________
Kristen Coleman
State Bar No.: 24038825
kcoleman@woodfilllaw.com
River Oaks Green
3131 Eastside St., Suite 450
Houston, Texas 77098
Telephone: 713-751-3080
Facsimile: 713-751-3058
Certificate of Conference
Pursuant to Tex. R. App. P. 10.1(5), this is to certify that I did not
confer with the individual Appellees, because they are not represented by
counsel.
/s/ Kristen S. Coleman
Kristen Coleman
Attorney for Appellant
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CERTIFICATE OF SERVICE
I hereby certify that on this 2nd day of July, 2015, a true and correct
copy of the foregoing document has been served on counsel below:
Via USPS First Class Mail
Gurnam Singh Sandhar
7 Harbor Bend Drive
Houston, Texas 77070
Via USPS First Class Mail
Inqlabi Thandi
9910 Oxted
Spring, Texas 77379
Via USPS First Class Mail
Daljit Singh Baganti
19027 Rustling Ridge Lane
Tomball, Texas 77377
Via USPS First Class Mail
Baljinder Singh Bhatti
14355 Cornerstone Village Dr. #911
Houston, Texas 77014
Via USPS First Class Mail
Sodagar Singh Virk
2413 Air Line Dr.
Brenham, Texas 77833
Via USPS First Class Mail
Baljinder Singh
12206 Winderwick
Houston, Texas 77066
Via Email
Briseida Luna
/s/ Kristen S. Coleman
Kristen Coleman
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