Country Title , L.L.C. v. Morenike Jaiyeoba ( 2015 )

ACCEPTED
01-14-00931-cv
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/22/2015 4:09:31 PM
CHRISTOPHER PRINE
CLERK
NO. 01-14-00931-CV
IN THE FIRST COURT OF APPEALS FILED IN
1st COURT OF APPEALS
AT HOUSTON, TEXAS HOUSTON, TEXAS
7/22/2015 4:09:31 PM
CHRISTOPHER A. PRINE
Clerk
COUNTRY TITLE, L.L.C.,
Appellant
VS.
MORENIKE JAIYEOBA,
Appellee
On Appeal from 268th Judicial District Court
Fort Bend County, Texas
Cause 07-DCV-159705
________________________________________________
SECOND MOTION FOR EXTENSION OF TIME TO FILE
APPELLEE’S BRIEF
[UNOPPOSED]
________________________________________________
TELTSCHIK!GRUBBS
L.T. Bradt #02841600
Betsy L. Grubbs #24032259
14015 Southwest Freeway, Suite 4
Sugar Land, Texas 77478
(281) 201-0700
Fax: (281) 201-1202
ltbradt@flash.net
grubbs@tlaw.us
Attorneys for Appellee
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Appellee asks the Court to extend the time to file Appellee’s Brief and
respectfully shows as follows:
1. Appellant is COUNTRY TITLE, L.L.C.; appellee is MORENIKE
JAIYEOBA.
2. The 268th Judicial District Court of Fort Bend County, Texas, signed
its Final Judgment on August 19, 2014, in favor of appellee and
against appellant.
3. On May 7, 2015, the Appellant’s Brief was filed.
4. The Appellee’s brief was due July 9, 2015, and this Motion for
Extension of Time is filed within the 15 day period to file the brief.
5. Appellee needs an extension of time due Counsel’s schedule:
a. June 12, 2015, prepared for and attended pre-trial conference
on Silkowski v. Joern, Cause No. 09CV1968, pending in the
212th Judicial District Court of Galveston County, Texas,
assigned for June 22, 2015.
b. June 15 - June 29, Prepared for and presented trial to jury
verdict, Silkowski v. Joern, Cause No. 09CV1968, pending in
the 212th Judicial District Court of Galveston County, Texas.
Trial began, June 22; verdict returned, June 29.
c. Assisted in the research and drafting of a Petition for
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Discretionary Review in four matters, PDR Granted June 10,
2015, Extension granted June 22, and brief now due July 27,
2015.
d. Assisted in the research and drafting of a Petition for Writ of
Certiorari to the Court of Criminal Appeals, filed July 14, 2015.
e. Appellee requests an additional 30 days to complete the brief,
to, through and including August 9, 2015.
CERTIFICATE OF CONFERENCE
6. A conference was held with Leslee Haas on the merits of this motion
and opposing counsel is unopposed to the extension requested.
D. Prayer
7. For these reasons, Appellee asks that the Court grant an extension
of time to file the brief until August 9, 2015. Appellee prays for
general relief.
Respectfully Submitted,
TELTSCHIK-GRUBBS, P.L.L.C.
/s/ L.T. “Butch” Bradt
L.T. Bradt #02841600, ltbradt@flash.net
Betsy L. Grubbs #24032259
14015 Southwest Freeway, Suite 4
Sugar Land, Texas 77478
(281) 201-0700
Fax: (281) 201-1202
ATTORNEYS FOR MORENIKE JAIYEOBA
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CERTIFICATE OF SERVICE
I, the undersigned attorney, certify that a true and correct copy of the
foregoing Second Motion to Extend time to file Appellee’s Brief was served
in accordance with Texas Rules of Appellate Procedure Rule 9.5, on:
Ms. Leslee Haas
Brianne W. Richardson
LeClair Ryan
1233 West Loop South, Suite 1000
Houston, Texas 77027
Via Facsimile to: (713) 650-0027
on July 22, 2015.
/s/ L.T. “Butch” Bradt
L.T. “Butch” Bradt
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