Joslyn M. Johnson, Individually and as for the Estate of Rodney Johnson v. City of Houston ( 2015 )

ACCEPTED
14-15-00176-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/7/2015 1:14:27 PM
CHRISTOPHER PRINE
CLERK
No. 14-15-00176-CV
FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
7/7/2015 1:14:27 PM
IN THE FOURTEENTH COURT OF CHRISTOPHER
APPEALS A. PRINE
Clerk
AT HOUSTON, TEXAS
JOSLYN M. JOHNSON, INDIVIDUALLY AND AS EXECUTRIX
FOR THE ESTATE OF RODNEY JOHNSON, DECEASED
Appellant
v.
CITY OF HOUSTON
Appellee
On Appeal from the 125TH Judicial District Court of Harris County,
Texas (Cause No. 2008-53919)
APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
Appellant asks the Court to extend the time to file her Brief.
1. This Motion is filed by Appellant pursuant to TEX. R. APP. P. 10.5
(b) and 38.6(d).
2. The matter is on appeal from the 125TH Judicial District Court in Harris
County, Texas; Cause No. 2008-53919 styled as Joslyn Johnson, Individually
and as Executrix for the Estate of Rodney Johnson v. City of Houston. The
final order made the basis of this appeal was signed by the trial court on
November 17TH 2014.
3. Appellant requests an extension of at least ONE HUNDRED TWENTY
DAYS (120) days from the original due date of May 1ST 2015 to file her brief.
4. This is the second extension sought by the Appellant.
5. The Appellee requested the trial court clerk to supplement the record
with additional documents. Those records were only made available recently,
and after the expiration of Appellant’s first extension.
For these reasons the Appellant respectfully requests the Court to grant
an extension to file her brief.
Respectfully submitted,
LAW OFFICES OF BEN DOMINGUEZ, II
BY:______________________
Ben Dominguez, II
SBN: 00786415
The Esperson Buildings
808 Travis, Suite 907
Houston, Texas 77002
Tel: (713) 224-7333
Fax: (832) 201-7071
Bdominguez@bendominguez.com
David M. Medina
SBN: 88
5800 Memorial Drive, Suite 890
Houston, Texas 77007
ATTORNEYS FOR APPELLANT
JOSLYN JOHNSON
CERTIFICATE OF CONFERENCE
I hereby certify that I telephoned Mr. John Wallace on 7th of July 2015 to
discuss this motion and I left a detailed message for the purpose of my call. I
have not received a return call regarding his position on this motion.
_______________________________
BEN DOMINGUEZ, II
CERTIFICATE OF SERVICE
I hereby certify that the foregoing instrument was served upon all
counsel of record via fax or ECF on July 7, 2015.
John B. Wallace
Sr. Assistant City Attorney
john.wallace@houstontx.gov
______________________________
BEN DOMINGUEZ, II