Laurel Miller and Eliana Miller v. Debo Homes, LLC ( 2015 )

ACCEPTED
14-15-00004-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/7/2015 10:30:52 AM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 14-15-00004-CV
FILED IN
14th COURT OF APPEALS
IN THE FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS
HOUSTON, TEXAS 7/7/2015 10:30:52 AM
CHRISTOPHER A. PRINE
Clerk
LAUREL MILLER AND ELIANA MILLER
Appellants
vs.
DEBO HOMES, LLC
Appellee
From Cause No. 13-DCV-209822
In the 400th Judicial District Court
Fort Bend County, Texas
APPELLEE’S FIRST UNOPPOSED MOTION TO ENLARGE THE TIME
FOR FILING THEIR REPLY BRIEF
Craig Welscher
State Bar No. 21167200
Nicholas Martinez
State Bar No. 24087986
The Welscher Law Firm, P.C.
1111 North Loop West, Suite 702
Houston, Texas 77008
(713) 862-0800 – Telephone
(713) 862-4003 – Facsimile
Email: nmartinez@welscherlaw.com
Attorneys for Appellee
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TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW DEBO HOMES, LLC, the Appellee in the above-numbered
and styled appeal, by and through their counsel of record, Nicholas Martinez, and
respectfully moves for an enlargement of thirty (30) days for the filing of their
reply brief to Appellants’ opening brief, and in support thereof would respectfully
show unto the Court the following:
1. Appellants’ opening brief was filed on June 8, 2015.
2. Appellee’s reply brief is now due on July 8, 2015.
3. Appellee’s opening brief is due on July 27, 2015
4. Appellee has been diligently working on preparing their opening brief in
preparation for the July 27 deadline. Appellee has not had the opportunity to
prepare their reply brief.
5. Counsel for Appellants graciously does not oppose this enlargement of the
Appellee’s briefing deadline.
PRAYER
Wherefore, premises considered, the Appellee, Debo Homes, LLC, prays
that the Court enlarge the deadline for the filing of their opening brief thirty (30)
days, through and including August 7, 2015.
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Respectfully submitted,
THE WELSCHER LAW FIRM
/s/ Nicholas Martinez
Craig Welscher
State Bar No. 21167200
Nicholas Martinez
State Bar No. 24087986
The Welscher Law Firm, P.C.
1111 North Loop West, Suite 702
Houston, Texas 77008
(713) 862-0800 – Telephone
(713) 862-4003 – Facsimile
Email: nmartinez@welscherlaw.com
Attorneys for Appellee
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CERTIFICATE OF CONFERENCE
The undersigned has conferred with Mr. Timothy A. Hootman about this
Motion. On July 2, 2015, Mr. Hootman advised over via email that he is
unopposed to this Motion.
/s/ Nicholas Martinez
Nicholas Martinez
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing
instrument was forwarded to all known counsel of record in the manner required
by Texas Rule of Appellate Procedure 9.5, on this the 7th day of July, 2015.
Via Electronic Service
Timothy A. Hootman
2402 Pease St.
Houston, Texas 77003
/s/ Nicholas Martinez
Nicholas Martinez
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