Cheryl E. Hill v. Federal National Mortgage Association (Fannie Mae), Nationstar Mortgage LLC ( 2015 )

ACCEPTED 14-15-00388-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/30/2015 10:35:33 AM CHRISTOPHER PRINE CLERK NO. 14-15-00388-CV IN THE FOURTEENTH COURT OF APPEALS FILED IN HOUSTON, TEXAS 14th COURT OF APPEALS HOUSTON, TEXAS 7/30/2015 10:35:33 AM CHERYL E. HILL, CHRISTOPHER A. PRINE Clerk Appellant, V. FEDERAL NATIONAL MORTGAGE ASSOCIATION, NATIONSTAR MORTGAGE LLC. Appellees. UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF On Appeal from Cause 2014-24269 In the 281ST Judicial District Court Of Harris County, Texas Hon. Sylvia Matthews, Judge Presiding RICARDO GUERRA Lead Counsel for Appellant State Bar No. 24074331 ERIC DAYS State Bar No. 24082907 BRENT SMITH State Bar No. 24083875 Law Offices of Rick Guerra 2211 Rayford Rd. Ste. 111 #134 Spring, TX 77386 Direct: 281-760-4295 FAX: 866-325-0341 Cheryl Hill TO THE HONORABLE FOURTEENTH COURT OF APPEALS: Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant, Cheryl Hill, files this Unopposed First Motion to Extend Time to File Appellant’s Brief. Appellant’s opening brief is currently due on August 5, 2015 Counsel for Appellant requests a 30-day extension of time to file its brief, making the brief due on September 4, 2015. This is the first request for extension of time to file the opening brief. 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: Counsel for Appellant has been participating in numerous depositions for litigation pending in numerous counties including Harris County, Hidalgo County, and Bexar County. Counsel has two trials scheduled in August, and counsel was responsible for preparing responses to dispositive motions in those two cases. Counsel also was responsible for an appellate brief in another matter that was filed on July 8, 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. The undersigned has conferred with opposing counsel, and he has indicated that his client does not oppose this motion. All facts recited in this motion are within the personal knowledge of the counsel signing this motion; therefore no verification is necessary under Rule of Appellate Procedure 10.2. PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Unopposed First Motion to Extend Time to File Appellant’s Brief and extend the Deadline for Filing the Appellant’s Brief up to and including September 4, 2015. Appellant all other relief to which it may be entitled. Respectfully submitted, Law Offices of Rick Guerra /s/ Ricardo Guerra Ricardo Guerra State Bar No. 24074331 Email: service@rickguerra.com 2211 Rayford Rd. Ste 111 #134 Spring, TX 77386 Direct: 281-760-4295 Fax: 866-325-0341 Attorney for Appellant CERTIFICATE OF CONFERENCE I certify that I conferred with counsel for Appellee regarding this motion and that Appellee is not opposed to this motion. /s/ Ricardo Guerra RICARDO GUERRA CERTIFICATE OF SERVICE I certify that on July 30, 2015, a true and correct copy of Unopposed First Motion for Extension of Time to File Appellant’s Brief was served by via e-filing on all counsel of record. /s/ Ricardo Guerra RICARDO GUERRA