the Discovery Group, Incorporated D/B/A Preferred Corporate Housing v. Richard Kammen, Individually and Dba Richard Kammen & Associates ( 2015 )

ACCEPTED 01-15-00243-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 5/1/2015 12:38:16 PM CHRISTOPHER PRINE CLERK NO . 01-15-00243-CV __________________________________________ FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE FIRST COURT OF APPEALS 5/1/2015 12:38:16 PM HOUSTON , TEXAS CHRISTOPHER A. PRINE ___________________________________________ Clerk THE DISCOVERY GROUP , INCORPORATED D /B /A PREFERRED CORPORATE HOUSING Appellant V. RICHARD KAMMEN , INDIVIUDALLY AND D /B /A RICHARD KAMMEN & ASSOCIATES Appellee. ___________________________________________ Appeal from the County Civil Court at Law Number Three (3) Harris County, Texas Trial Court Cause No. 1029597 ___________________________________________ FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF ___________________________________________ Andrew P. McCormick Laurie A. Munoz McCormick, Lanza & McNeel, LLP 4950 Bissonnet Street Bellaire, TX 77401 (713) 523-0400 (713) 523-0408 Fax Attorneys for Appellee, Richard Kammen, individually and d/b/a Richard Kammen & Associates UNOPPOSED MOTION TO EXTEND TIME FOR FILING APPELLEE’S BRIEF TO THE HONORABLE COURT OF APPEALS: Richard Kammen, individually and d/b/a Richard Kammen & Associates, Appellee, moves this court to grant an extension of time to file Appellee's Brief, and respectfully states: 1. Appellee’s Brief is due to be filed with this Court on May 8, 2015. 2. Appellee, Richard Kammen, individually and d/b/a Richard Kammen & Associates, seeks a 20-day extension of time to file Appellee's Brief, which would make Appellee's Brief due on or before May 22, 2015. 3 This extension of time is necessary because due to time constraints and the time required to conduct the research. It will be difficult for counsel for Appellee, Richard Kammen, individually and d/b/a Richard Kammen & Associates, to adequately prepare the brief in this appeal if the extension is not granted. Therefore, additional time is needed to adequately prepare the arguments in this case. 4. Counsel for Richard Kammen, individually and d/b/a Richard Kammen & Associates has conferred with the counsel for Appellant, The Discovery Group, Incorporated d/b/a Preferred Corporate Housing, and he is unopposed to the motion to extend time. 5. This is the first extension of time Appellee has sought for the filing of the Appellee's Brief. 2 PRAYER FOR RELIEF For the reasons set forth above, Appellee requests that this court render an order extending the time for filing Appellee Richard Kammen, individually and d/b/a Richard Kammen & Associates’s Brief to and including May 22, 2015. Appellee also requests any other relief to which it may be entitled. Respectfully submitted, MC CORMICK, LANZA & MC NEEL, LLP By: /s/ Andrew P. McCormick ANDREW P. McCORMICK State Bar No. 13457100 amccormick@mlm-lawfirm.com LAURIE A. MUNOZ State Bar No. 24071782 lmunoz@mlm-lawfirm.com 4950 Bissonnet Street Bellaire, Texas 77401 (713) 523-0400 / (713) 523-0408 Attorneys for Appellee Richard Kammen, individually and d/b/a Richard Kammen & Associates CERTIFICATE OF CONFERENCE As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have conferred with opposing counsel regarding this request and that Steven D. Poock, counsel for Appellant, does not oppose this motion. /s/ Laurie A. Munoz LAURIE A. MUNOZ 3 CERTIFICATE OF SERVICE I certify that I have served this document on all other parties, which are listed below on May 1, 2015 via email and/or facsimile as follows: Steven D. Poock Attorney at Law P. O. Box 984 Sugar Land, TX 77487 /s/ Laurie A. Munoz LAURIE A. MUNOZ 4