Ali Rassouli v. National Signs Holdings, LLC, National Signs, LLC, Louis Girard ( 2015 )

ACCEPTED
14-15-00353-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/30/2015 11:24:26 AM
CHRISTOPHER PRINE
CLERK
CASE NO. 14-15-003530-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FOURTEENTH DISTRICT OF TEXAS
7/30/2015 11:24:26 AM
AT HOUSTON CHRISTOPHER A. PRINE
Clerk
ALI RASSOULI,
Appellant
v.
NATIONAL SIGNS HOLDINGS, LLC, NATIONAL SIGNS, LLC, LOUIS
GIRARD
Appelllee
On Appeal From The
rd
133 District Court of Harris County, Texas
Cause No. 2014-42950
FIRST MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT’S BRIEF
LLOYD E. KELLEY
THE KELLEY LAW FIRM
2726 Bissonnet Ste 240 PMB 12
Houston, Texas 77005
281-492-7766 telephone
281-652-5973 facsimile
kelley@lloydekelley.com
Attorney for Appellant
TO THE HONORABLE SUPREME COURT OF TEXAS:
Appellant, Ali Rassouli respectfully files this Motion for Extension of Time
to file his brief and shows the Court as follows:
I. REQUEST FOR EXTENSION OF TIME
Appellant’s brief is currently due on July 31, 2015. Counsel for Appellant
respectfully requests a 30-day extension of time to file his brief, making the brief
due on August 30, 2015. This is the first request for extension of time to file
Appellant’s brief.
II. ARGUMENT
Counsel for Appellant relies on the following reasons, in addition to the
routine matters that counsel must attend to in daily practice, to explain the need for
the requested extension:
Appellant’s counsel had been preparing for trial set to commence in Cause
No. 2009-71319A; Abdee Sharifan v. JM Little, In the 333rd Judicial District
Court, Harris, County, Texas on July 20, 2015. On the eve of trial said case was
settled.
2
Additionally, Appellant’s counsel has been preparing a response brief to a
mandamus in No. 14-15-00535-CV, The Law Office of Art Dula, et al v. Horie,
Takafumi, In the Fourteenth Court of Appeals, due on August 10, 2015.
Counsel for Appellant seeks this extension of time to be able to prepare a
cogent and succinct brief to aid this Court in its analysis of the issues presented.
This request is not sought for delay but so that justice may be done.
PRAYER FOR RELIEF
For the reasons set forth above, Appellant respectfully requests that this
Court grant this First Motion to Extend Time to File Appellant’s Brief and extend
the Deadline for Filing Appellant’s Brief up to and including August 30, 2015.
Appellant hereby requests all other relief to which he may be entitled.
Respectfully submitted,
THE KELLEY LAW FIRM
By: _/s/ Lloyd E. Kelley____
LLOYD E. KELLEY
State Bar No. 11203180
2726 Bissonnet Ste 240 PMB 12
Houston, Texas 77005
281-492-7766 telephone
281-652-5973 facsimile
Attorney for Appellant
3
CERTIFICATE OF CONFERENCE
I hereby certify that I have conferred with counsel for the Appellee on July ,
30, 2015, concerning this motion for extension of time. Counsel John H.
McFarland is opposed.
_/s/ Lloyd E. Kelley_____________
Lloyd E. Kelley
CERTIFICATE OF SERVICE
I hereby certify that on the 30th day of July, 2015, a true and correct copy of
the foregoing, Appellant’s Motion for Extension of Time to Brief, was served via
e-mail upon the following:
John H. McFarland
Joyce+McFarland LLP
jmcfarland@jmlawyers.com
_/s/Lloyd E. Kelley_____________
Lloyd E. Kelley
4