Kimberly R. Redo v. Katherine Moore ( 2015 )

ACCEPTED
14-14-00922-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
6/1/2015 12:03:00 PM
CHRISTOPHER PRINE
CLERK
No. 14-14-00922-CV
____________________________
FILED IN
IN THE COURT OF APPEALS FOR THE 14th COURT OF APPEALS
HOUSTON, TEXAS
FOURTEENTH DISTRICT OF TEXAS
6/1/2015 12:03:00 PM
CHRISTOPHER A. PRINE
Clerk
Kimberly R. Redo
Appellant,
v.
Katherine Moore
Appellee.
On Appeal from County Court at Law No. One (1)
Of Harris County, Texas
Trial Court Cause No. 1029105
UNOPPOSED
SECOND MOTION FOR EXTENSION OF
TIME TO FILE BRIEF OF APPELLANT
TO THE HONORABLE JUSTICES OF THIS COURT:
Kimberly R. Redo, Appellant, file this Unopposed Motion for Extension of Time to File
Brief of Appellant and would show the Court as follows:
1. Appellant’s brief is due on Monday, June 1, 2015.
2. Appellant respectfully requests an extension of time for 30 days to file her brief.
3. In addition to his regular office and client commitments and responsibilities,
counsel for Appellant has been required to prepare for and attend to various other matters
including:
APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 1
(a) Attend trial in Cause No. 2013-22591, styled Capital Plastic & Bags, Inc. v. Frank
Zhang and Daxwell Group, LLC, f/k/a Daxwell Group, L.P., pending in the 295th
Judicial District Court of Harris County, Texas.
(b) Prepare for and attend depositions in Cause No. 2012-11729, styled PMB Precision
Medical Billing v. Bay Area Podiatry Associates, pending in the 165th Judicial
District Court of Harris County, Texas.
(c) Prepare for and attend non-party deposition in Cause No. 2014-50460, styled 6100
Clarkson L.P., et. al. v. Melvin Grant, et al., pending in the 295th District Court of
Harris County, Texas.
(d) Prepare for and attend pre-trial conference in Case No. 4:15-cv-859, styled Carmelita
Sagum v. Deutsche Bank National Trust Company, pending in the United States
District Court for the Southern District of Texas, Houston Division.
(e) Prepare for and attend oral argument in Cause No. 2009-65488 in Case No. 14-14-
00744-CV, styled Mega Builders, Inc., d/b/a Mega & Associates v. Paramount
Stores, Inc., and Community National Bank; In Fourteenth Court of Appeals.
(f) Prepare for and travel overseas to the Netherlands and Belgium, having left on
Friday, May 15, 2015, and returning on Sunday, May 24, 2015.
In addition to the above, the undersigned counsel has the following upcoming deadlines:
(g) Prepare a response to Motion for Summary Judgment and attend Summary Judgment
hearing on June 5, 2015, in Cause No. 2014-16000; styled Heritage Park Terrace
Homeowners Association vs. Mohammad F. Akbar, pending in the 113th Judicial
District of Harris County, Texas.
(h) Prepare for and attend TCEQ hearing in SOAH Docket No. XXX-XX-XXXX; TCEQ
Docket No. 2014-0908-PST-E, styled In the Matter of an Enforcement Action Against
Adnan Najm d/b/a Kathy’s Sunmart, RN101943140, on June 11, 2015.
(i) Prepare for and attend hearing on Harris County’s Motion for Summary Judgment on
June 12, 2015, in Cause No. 2011-52524, styled Harris County, Texas, Plaintiff, vs.
S.K. and Brothers, Inc., and Trey Melcher and Yvonne Evie Melcher, Trustees of the
Evie Melcher Non-Exempt Trust, Defendants, pending in the 215th Judicial District
Court, of Harris County, Texas.
(j) Prepare Joint Pre-Trial Statement in Adversary Case No. 14-03320, styled Gulam
Gulamali v. Ngo Xuan Dinh and Nina Nhathuy Dinh, pending in the Southern District
of Texas, which is due June 19, 2015.
APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 2
(k) Attend hearing on June 19, 2015, in Cause No. 14-DCV-214552, styled In the Matter
of the Marriage of Edward Ochuwa and Nwabugwu Ochuwa, pending in the 328th
Family District Court of Fort Bend County, Texas.
4. One previous extension for time was granted to Appellant on April 13, 2015, with
regard to the filing of her brief.
5. This Motion is not sought for delay only, but in order that justice may be properly
served.
PRAYER
Appellant Kimberly R. Redo, respectfully requests that this Court grant her request for an
extension of 30 days, until Wednesday, July 1, 2015, to file her brief. Appellant prays for any
other relief to which it is entitled.
Respectfully submitted,
WILLIAM F. HARMEYER & ASSOCIATES
/s/William F. Harmeyer
William F. Harmeyer
State Bar No. 09019000
475 Arena Tower One
7322 Southwest Freeway
Houston, Texas 77074
Tel: (713) 270-5552
Fax: (713) 270-7128
Email: wharmeyer@harmeyerlaw.com
Attorney for the Appellant,
Kimberly R. Redo.
APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 3
CERTIFICATE OF CONFERENCE
I hereby certify that I have contacted Mr. Steven Messer, attorney for Appellee,
Katherine Moore, as to the merits of the forgoing motion, and that he is unopposed to this
Motion for Extension of Time to File Appellant’s Brief.
/s/William F. Harmeyer
William F. Harmeyer
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served on the
following parties or counsel of record on this 1st day of June, 2015, in accordance with Rule 9.5
of the Texas Rules of Appellate Procedure.
Mr. Steven Messer
Haynes and Boone, LLP
1221 McKinney, Suite 2100
Houston, Texas 77010-2007
Attorney for Appellee,
Katherine Moore
Via Fax: (713) 236-5507
/s/William F. Harmeyer
William F. Harmeyer
APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 4