Frank M. Seliger v. Ethiopian Evangelical Church ( 2015 )

ACCEPTED 03-14-00621-CV 4848160 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/10/2015 3:09:40 PM JEFFREY D. KYLE CLERK NO. 03-14-00621CV FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS 4/10/2015 3:09:40 PM THE 1HlRD DISTRICT OF 1EXAS JEFFREY D. KYLE AUSTIN, 1EXAS Clerk FRANK SELIGER, Appellant v. THE ETHIOPIAN EVANGELICAL CHURCH, Appellee. Appeal from the County Court at Law Number One Travis County, Texas Trial Court Case No. C-1-CV-14-005819 Hon. David Phillips, presiding APPELLEE'S MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF TO THE HONORABLE COURT OF APPEALS: COMES NOW APPELLEE, ETHIOPIAN EVANGELICAL CHURCH, who files this Motion for Extension of Time to File its Appeal Brief and respectfully shows the following: 1. Appellee's deadline to file its Appeal Brief is April 10, 2015. Appellee's Motion for Extension of Time to File Appellee's Brief Page 1 2. Part of the practice of Appellee's counsel involves a foreclosure prevention program. Due to the large volume of client facing foreclosure during the month of April, 2015, counsel for Appellee is in need of additional time to complete and file the Appellee's Appeal Brief. 3. Appellee requests a two-week extension of time on which to file its Appeal Brief to April24, 2015. WHEREFORE, PREMISES CONSIDERED, Appellee prays this Court grant its Motion for Extension of Time to File its Appeal Brief and extend its deadline to file same to April 24, 20 15. Respectfully submitted, By: Is/ James Minerve James Minerve State Bar No. 24008692 115 Saddle Blanket Trail Buda, Texas 78610 (210) 336-5867 (888) 230-6397 (Fax) Attorney for Appellee CERTIFICATE OF CONFERENCE On April 09, 2015, the undersigned counsel for Appellee conferred with pro se Appellant, Fran Seliger, concerning the foregoing Motion and Mr. Seliger stated that he is not opposed to this Motion. See Exhibit A. I sf James Minerve James Minerve Appellee's Motion for Extension of Time to File Appellee's Brief Page 2 CERTIFICATE OF SERVICE I hereby certify that on this 1Oth day of April, 2015 a true and correct copy of the above and foregoing document was sent via Efile.txcourts.gov electronic filing notification system and via e-mail to the parties of record listed below: Appellant Pro Se: Frank Seliger 21 08 East Yager Lane Austin, Texas 78754 E-mail: digitalfranks@att.net I sf James Minerve James Minerve Appellee's Motion for Extension of Time to File Appellee's Brief Page 3 -- -- - - ·- - EXHIBIT A Maria Rogers From: Frank Seliger Sent: Thursday, April 9, 2015 12:20 PM To: Maria Rogers Subject: RE: (Ethiopian Church/Seliger) REQUEST FOR EXTENSION TO FILE APPEAL BRIEF ON BEHALF OF ETHIOPIAN CHURCH Hi Maria. No probiem on th e extension. You a!! were very nice about my Appeliant's Brief extension ... so I will gladly do the same for you. If you need more t ime than the t wo weeks ... just let me know. Helping people with foreclosure problems is important work. Good luck in vour efforts. Yours sincerely, Frank Seliger From: Maria Rogers [mailto:mr@minervelaw.com] Sent: Thursday, April9, 2015 9:35AM To: digitalfranks@att.net Cc: Kevin Gates; James Minerve; James Minerve Subject: (Ethiopian Church/Seliger) REQUEST FOR EXTENSION TO FILE APPEAL BRIEF ON BEHALF OF ETHIOPIAN CHURCH Importance: High Mr. Seliger: Our deadline to file the appeal brief for our client is this Friday, April lOth. Due to the large volume of clients we had this past Tuesday facing foreclosure on that day, we had to shift gears and work towards stopping the foreclosures for these clients and we now need additional time to complete and file our appeal brief. We are requesting your agreement to a two week extension oftime to file our brief. That would put our deadline to Friday, April 24th. We agreed to your request for extension of time to file in this case and we hope that you will reciprocate. Thank you in advance for your courtesy. Sincerely, Maria Rogers Legal Assistant The Minerve Law Firm 115 Saddle Blanket Trail Buda, Texas 78610 Tel: 888-819-1440 Ext. 102 Fax: 888-230-6397 Ema-iJ: DJ.r.@~Kil~J:1©.r\:f~?:Yi~S:!21l Website: .c.:.c":~c.;..:.:.:..:~·: : :_o,,,...,-"~'~-'·'·"·'··"!'''··-'·c 1