Aaron Chevalier v. W.M. Roberson ( 2015 )

FILED IN
1ST COURT OF APPEALS
HOUSTON. TEXAS
NOV 16 2015
CHRISTSPHEH^A. BRINE
Case No. 01-15-00225-CV
CLER
Aaron Chevalier IN THE COURT OF APPEALS
Appellant-Tenant
Vs FIRST JUDICIAL DISTRICT
W M Roberson,
Appellee-Landlord (ProSe) HOUSTON, TEXAS
On Appeal from Judgment No. 1058132
County Civil Court at Law No. One
Hon. Debra Ibarra Mayfield, Judge
Houston, Texas
APPELLEE'S MOTION TO FILE FIRST AMENDED BRIEF
MAY IT PLEASE THE HONORABLE COURT:
W M Roberson, appellee-landlord (pro se), respectfully submits this Motion to
File First Amended Brief under the Tex. R. App. P. 38.7, showing:
Both parties obtained 30-days extension of time to file the Appellant's brief
on August 25,2015, and the Appellee's brief on Oct. 26, 2015. Appellee will need
an extension of time to review the Appellant's cited case laws, and prepare his
defense, and no other extension except for Appellant's has been previously
requested. The TEX. R. APP. P. 38.1(g) states that the statement of facts portion
of an appellant's brief "must be supported by record references." Appellant's
Brief violates this rule by providing no recorder's record citations.
Therefore, the Appellant has had to review his notes and over 200-pages of
exhibits, and after double-checking the briefs' facts, laws, and citations, there are
errors and omissions therein which should be amended in the interest of justice.
Moreover, this case has not been set for submission to a panel of this
Court, and no harm will result from granting this motion to file the accompanying
First Amended Brief submitted herewith.
WHEREFORE, the Court should grant this request and order that the First
Amended Brief is timely filed on today's date, to wit: Nov. l(f, 2015.
Certificate of Service
On this day I certify that a copy of this document was mailed to counsel of
record, Nasischa Biscette, 1811 Bering Dr., #300, Houston, TX 77057.
Certificate of Conference
On this day I certify that I have conferred or made a reasonable attempt to
confer with all counsel of record about the merits of this motion which is
unopposed or un-responded to.
Respectfully submitted,
/WM Dated: Udldf.
W M Roberson
P.O. Box 842583
Houston, Texas 77284-2583
Appellee-Landlord (Pro Se)
FILED IN
1ST COURT OF APPEALS
HOUSTON, TEXAS
Nov. ]£ 2015 NOV 16 2015
CHRIST0PHEaA£RINE
Hon. Christopher A. Prine cleri<
Clerk of the Court
First Court of Appeals
301 Fannin Street
Houston, Texas 77002-2066
RE: Case No. 01-15-00225-CV, Aaron Chevalier -vs- W M Roberson
TC #1058132, Co. Civ. Ct. at Law No. 1, Hon. Debra I. Mayfield, Judge
Dear Hon. Clerk;
Please file in the above referenced case, an original plus 4-copies of:
1) APPELLEE'S MOTION TO FILE AMENDED BRIEF, And
2) FIRST AMENDED BRIEF FOR APPELLEE (PRO SE),
Also enclosed is my $10.00 money order for the filing fee.
Counsel of record was served by certificate of service.
Your courteous assistance Is greatly appreciated!
Respectfully,
W M Roberson
P.O. Box 842583
Houston, TX 77284-2583
Appellee (Pro Se)