Nationwide Distribution Services, Inc. v. Robert Jones and Poly Trucking, Inc. ( 2015 )

ACCEPTED
01-15-00232-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/25/2015 11:22:33 AM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 01-15-00232-CV
________________________________________
FILED IN
1st COURT OF APPEALS
IN THE FIRST COURT OF APPEALS IN HOUSTON, TEXASHOUSTON, TEXAS
6/25/2015 11:22:33 AM
________________________________________
CHRISTOPHER A. PRINE
Clerk
NATIONWIDE DISTRIBUTION SERVICES, INC.,
Appellant,
v.
ROBERT JONES AND POLY TRUCKING, INC.,
Appellees.
________________________________________
On appeal from the 133rd Judicial District Court of Harris County, Texas
________________________________________
UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE
BRIEF OF APPELLEE, POLY TRUCKING, INC.
________________________________________
Tracy J. Willi
Texas Bar No. 00784633
Willi Law Firm, P.C.
9600 Escarpment Blvd., Suite 745, PMB 34
Austin, TX 78749-1983
Tel. (512) 288-3200
Fax (512) 288-3202
twilli@willi.com
ATTORNEY FOR APPELLEE,
POLY TRUCKING, INC.
UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME
Poly Trucking, Inc., Appellee, files this Unopposed Second Motion for
Extension of Time to File Brief of Appellee, Poly Trucking, Inc., and would show
this Court as follows.
This is an interlocutory appeal of an Order denying a Special Appearance.
The Order was signed on February 23, 2015. Nationwide Distributions Services,
Inc. (NDS) filed its Notice of Appeal on March 6, 2015.
The Brief of Appellee, Poly Trucking, Inc., is currently due on June 29, 2015.
This Court has granted a second extension of time for the Brief of Appellee, Robert
Jones, to be filed on July 29, 2015.
Poly Trucking, Inc. requests this extension of time in order to incorporate
matters contained in the supplemented record prior to filing the Brief of Appellee,
Poly Trucking, Inc., and to maintain the same briefing schedule as Appellee, Robert
Jones.
Therefore, Poly Trucking, Inc. requests this Court to extend the deadline to
July 29, 2015, to file the Brief of Appellee, Poly Trucking, Inc.
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Respectfully submitted,
/s/ Tracy J. Willi
Tracy J. Willi
Texas Bar No. 00784633
Willi Law Firm, P.C.
9600 Escarpment Blvd., Ste.745, PMB 34
Austin, TX 78749
Tel. (512) 288-3200
Fax (512) 288-3202
twilli@willi.com
ATTORNEY FOR APPELLEE,
POLY TRUCKING, INC.
CERTIFICATE OF CONFERENCE
I hereby certify that Counsel for Appellant, Nationwide Distribution Services,
Inc., and Counsel for Appellee, Robert Jones, are not opposed to this motion.
/s/ Tracy J. Willi
Tracy J. Willi
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CERTIFICATE OF FILING AND SERVICE
I hereby certify that this document was filed with Clerk of Court through the
Court’s electronic filing system and served on opposing counsel by the same manner
or, if counsel is not registered for service through the electronic filing system, then
by facsimile on June 25, 2015 as follows:
Robert L Ramey
Jack McKinley
Ramey Chandler Quinn & Zito, P.C.
750 Bering Dr., Ste. 600
Houston, TX 77057
Tel. (713) 266-0074
Fax (713) 266-1064
Counsel for Appellant, Nationwide Distribution Services, Inc.
Cory Daniel Itkin
Arnold & Itkin LLP
6009 Memorial Dr.
Houston, TX 77007
Tel. (713) 222-3800
Fax (713) 222-3850
Counsel for Appellee, Robert Jones
Chad Flores
Russell S. Post
Beck Redden LLP
1221 McKinney, Suite 4500
Houston, TX 77010
Tel. (713) 951-3700
Fax (713) 951-3720
cflores@beckredden.com
rpost@beckredden.com
Counsel for Appellee, Robert Jones
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Ruark D. Mershon
2000 W. Marshall Dr.
Grand Prairie, TX 75051
Tel. (971) 337-7692
Fax (972) 337-8139
Co-Counsel for Appellee, Poly Trucking, Inc.
/s/ Tracy J. Willi
Tracy J. Willi
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