Leticia B. Loya v. Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A. and Tinsel Group, S.A. ( 2015 )

ACCEPTED 01-14-01014-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/1/2015 2:12:04 PM CHRISTOPHER PRINE CLERK No.01-14-01014-CV FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE COURTOF ApPEALS 4/1/2015 2:12:04 PM FOR THEFIRST DISTRICTOFTEXAS CHRISTOPHER A. PRINE AT HOUSTON Clerk LETICIALoy A, Appellant, v. IANTAYLOR,JACOBUSSTERKEN,STICHTINGTINSELGROUP,VITOL HOLDINGII S.A., AND TINSELGROUP,S.A., Appellees. Appeal from the 190th Judicial District Court, Harris County, Texas Trial Court Cause No. 2012-33464 UNOPPOSED FIRST MOTION TO EXTEND TIME FOR FILING APPELLANT'S REPLY BRIEF TO THE HONORABLE FIRST COURT OF APPEALS: LETICIA LoyA, Appellant, moves this Court to grant an extension of time to file Appellant's Reply Brief, and respectfully states: 1. Appellant's Reply Brief is due to be filed with this court on April 14, 2015. 2. Appellant seeks a 20-day day extension of time to file Appellant's Brief, which would make Appellant's Brief due on or before May 4,2015. 1 3. This extension of time is necessary because lead counsel for Appellant was/is participating in several oral arguments, appeals and/or trials with deadlines prior to April 14, 2015 deadline, including but not limited to: • Universal Gold Coin v. FedEx et al, Western District of Tennessee (Daubert and pre-trial motions) • Filer v. Keystone Corporation, New York State Supreme Court, (pretrial motions and hearings) • Altamirano v. KONE, 136th Judicial District of Texas (eleven depositions, discovery deadline approaching) • Raja v. Kolander, 172nd Judicial District of Texas (trial) • Reado v. Lopez, 136th Judicial District of Texas (trial) As a result, time constraints will make it difficult to adequately prepare the reply brief in this appeal. This request is not filed for the purpose of delay, but rather to afford counsel adequate time to prepare the brief. Therefore, additional time is needed to adequately prepare the arguments in this case. 4. Counsel for Appellant has conferred with counsel for Appellees Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and Tinsel Group, S.A., and Appellees do not oppose this motion to extend time. 5. This is the first extension of time Appellant has sought for the filing of the Appellant's Reply Brief. For these reasons, LETICIA Loy A, Appellant, requests that this Court render an order extending the time for filing Appellant's Reply Brief to and 2 including May 4, 2015. Appellant also requests any other relief to which she may be entitled. Respectfully submitted, PROVOST *UMPHREY LAW FIRM, L.L.P. 490 Park Street P. O. Box 4905 Beaumont, Texas 77704 (409) 835-6000 (409) 813-8682 (FAX) By: / s / Jenniter Job Jennifer Job Texas State Bar No. 24050682 James Payne Texas State Bar No. 00788171 ATTORNEYS FOR APPELLANT CERTIFICATE OF CONFERENCE I hereby certify that I conferred with counsel for Appellees Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and Tinsel Group, S.A. concerning this motion, and Appellees do not oppose the relief requested in this motion. / s / Jennifer Job CERTIFICATEOF SERVICE I hereby certify that a copy of this motion to amend notice of appeal has been sent to all known counsel of record via EFILE and/or certified mail, return receipt requested on April 1, 2015. / s / Jennifer Job Jennifer Job 3