Michelle Kim v. Kum Sun Hendrickson ( 2015 )


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  •                                                                                                            ACCEPTED
    05-13-01024-CV
    FIFTH COURT OF APPEALS
    DALLAS, TEXAS
    7/9/2015 2:07:15 PM
    LISA MATZ
    CLERK
    CAUSE NO. 05-13-01024-C
    MICHELLE KIM                                 §    IN THE COURT OF APPELAS
    FILED IN
    Appellant and Counter-Appellee,         §                          5th COURT OF APPEALS
    §                              DALLAS, TEXAS
    §                          7/9/2015 2:07:15 PM
    VS.                                          §    FIFTH DISTRICT      OF TEXASLISA MATZ
    §                                  Clerk
    §
    KUM SUN HENDRICKSON                          §
    Appellee and Counter-Appellant.        §    AT DALLAS, TEXAS
    APPELLEE AND COUNTER-APPELLANT’S MOTION TO EXTEND TIME TO FILE
    MOTION FOR RE-HEARING
    TO THE HONORABLE COURT OF APPEALS:
    COMES now Kum Sun Hendrickson, Appellee and Counter-Appellant, pursuant to Rules
    49.1, 49.8, and 10.5(b), Texas Rules of Appellate Procedure, and would show the following:
    CERTIFICATE OF CONFERENCE
    1. Appellee’s counsel did confer with Appellant’s counsel two days ago considering this
    motion, and he was of the opinion that the time deadline for this motion had already
    expired; however, Appellee’s counsel learned that the deadline was not 10 days but 15
    days from the rendition of the judgment.
    2. It is presumed that Appellant’s counsel is opposed to this motion.
    I.     GROUNDS FOR MOTION
    3. Judgement was rendered on June 25, 2015.
    4. The deadline to file a motion for re-hearing is fifteen (15) days thereafter, or July 10,
    2015.
    5. Within that period of time, this motion is timely filed and seeks an extension of time for
    the reason that Appellee’s counsel is currently in the hospital and is not expected to
    return to practice for a minimum of 2 weeks.
    6. There have been no previous requests to extend time to file a motion for re-hearing.
    7. Counsel for Appellee will provide medical proof thereof if requested by this court.
    MOTION TO EXTEND TIME TO FILE MOTION FOR REHEARING
    Page - 1
    II.     REQUESTED RELIEF
    8. Appellee request until July 31, 2015 to file a motion for re-hearing.
    9. Appellee requests that this motion be granted and for general relief.
    Respectfully submitted,
    THE LINE LAW FIRM
    6220 Gaston Avenue, Suite 609
    Dallas, Texas 75214
    214-821-2882 (Office – Main)
    214-682-0880 (Direct)
    214-821-2882 (Fax)
    By:    ______________________________
    David K. Line, Attorney at Law
    SBN: 12385500
    MOTION TO EXTEND TIME TO FILE MOTION FOR REHEARING
    Page - 2
    CERTIFICATE OF SERVICE
    I, the undersigned attorney, do hereby certify that a true and correct copy of the foregoing
    pleading has been served upon all counsel of record in accordance with Rule 21a, Texas Rules of
    Civil Procedure, to-wit:
    Emil Lippe
    Attorney for Appellant
    600 N. Pearl Street
    Suite S2460
    Dallas, Texas USA 75201
    View Map to our location
    Telephone: (214) 855-1850
    Facsimile: (214) 720-6074
    E-mail: emil@texaslaw.com
    Via:    Fax and E-mail
    Date: January 27, 2014
    ___________________________________
    David Line, Attorney
    MOTION TO EXTEND TIME TO FILE MOTION FOR REHEARING
    Page - 3
    

Document Info

Docket Number: 05-13-01024-CV

Filed Date: 7/9/2015

Precedential Status: Precedential

Modified Date: 9/29/2016