Jarrod Dale Young v. Kathryn Renee Terral ( 2014 )

ACCEPTED
01-14-00591-cv
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/31/2014 11:47:02 AM
CHRISTOPHER PRINE
CLERK
In the
COURT OF APPEALS
FOR THE
First District of Texas FILED IN
1st COURT OF APPEALS
____________ HOUSTON, TEXAS
12/31/2014 11:47:02 AM
NO. 01-14-00591-CV CHRISTOPHER A. PRINE
Clerk
____________
JARROD DALE YOUNG, Appellant
V.
KATHRYN RENEE TERRAL, Appellee
______________________________________
On Appeal from the 247th District Court
Harris County, Texas
Trial Court Cause No. 2012-37683
________________________________________________
APPELLEE’S SECOND
AGREED MOTION TO EXTEND TIME
TO FILE APPELLEE’S BRIEF
K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 1 OF 4
NO. 01-14-00591
JARROD DALE YOUNG, § IN THE DISTRICT COURT
APPELLANT §
§
V. § 247TH JUDICIAL DISTR
§
KATHRYN RENEE TERRAL §
APPELLEE § HARRIS COUNTY, TEXAS
APPELLEE’S SECOND AGREED MOTION TO EXTEND TIME
TO FILE APPELLEE’S BRIEF
Appellee, KATHRYN RENEE TERRAL, asks the Court to extend the time
to file its brief and respectfully shows the following:
A. INTRODUCTION
1. Appellant is JARROD DALE YOUNG; Appellee is KATHRYN RENEE
TERRAL.
2. Appellee’s brief is due on January 2, 2015.
3. Appellee respectfully requests an additional 30 days to file its brief, extending
the time until February 2, 2015.
4. The parties have agreed to this motion.
B. ARGUMENT & AUTHORITIES
5. Appellee's attorney Terisa Taylor of The Law Office of Terisa Taylor, P.C.,
needs additional time to file its brief because Appellee’s attorney has an unusually
heavy docket, staff attorney on vacation, and the research, preparation, and drafting
K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 2 OF 4
off the Appellee's brief will be disrupted by the heavy docket and absent of the staff
attorney.
6. One extension has been granted to extend the time to file Appellee's brief.
7. Appellee's Second Agreed Motion to Extend Time to File Appellee's Brief is
not sought for delay, but so that the interest of justice may be served.
C. PRAYER
4. For these reasons, KATHRYN RENEE TERRAL, asks this Court to grant an
extension of time to file response to appellant’s brief.
Respectfully submitted,
The Law Office of Terisa Taylor, P.C.
917 Franklin Street, Suite 510
Houston, Texas 77002
Tel: (713) 224-9900
Fax: (713) 224-9903
Email: service@ttaylorlawoffice.net
By: /s/ Terisa Taylor
TERISA TAYLOR
SBN: 24000240
GRACE M. CRUMP
SBN: 24083482
Counsel for: Appellee
K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 3 OF 4
CERTIFICATE OF CONFERENCE
I hereby certify that I have conferred with Melissa E. Loveless’ staff via
telephone on December 31, 2014, and she has agreed and is unopposed to this Agreed
Motion to Extend Time to File Appellee’s Brief.
/s/ Terisa Taylor``
TERISA TAYLOR
GRACE M. CRUMP
CERTIFICATE OF SERVICE
I hereby certify that on the 31st day of December, 2014, a true and correct copy
of the foregoing instrument was served upon each attorney of record or party in
accordance with the Texas Rules of Civil Procedure.
/s/ Terisa Taylor``
TERISA TAYLOR
GRACE M. CRUMP
K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 4 OF 4