Inwood Forest Community Improvement Association v. Toan Van Nguyen ( 2015 )

ACCEPTED
14-14-00825-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/7/2015 1:19:45 PM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00825-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS
FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS,
7/7/2015 1:19:45 PM
HOUSTON, TEXAS CHRISTOPHER A. PRINE
Clerk
INWOOD FOREST COMMUNITY IMPROVEMENT ASSOCIATION,
Appellant
v.
ELIO ARCE, ET AL.
Appellees
On interlocutory appeal from the
165th Judicial District Court of Harris County, Texas
______________________________________________________________
APPELLANT’S MOTION FOR EXTENSION
OF TIME TO FILE REPLY BRIEF ON THE MERITS
______________________________________________________________
HOOVER SLOVACEK LLP
Dylan B. Russell
State Bar No. 24041839
russell@hooverslovacek.com
Galleria Tower II
5051 Westheimer, Suite 1200
Houston, Texas 77056
Telephone: (713) 977-8686
Facsimile: (713) 977-5395
ATTORNEYS FOR APPELLANT
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INWOOD FOREST COMMUNITY IMPROVEMENT ASSOCIATION,
Appellant, in the above-styled and numbered cause, file this Appellant’s Motion for
Extension of Time to File Reply Brief on the Merits and requests that the Court enter
an order extending the time for the filing of its Reply Brief with the Court through,
and including, July 17, 2015, and in support thereof would respectfully show the
following:
1. This is Appellant’s first request for an extension of time—for one
additional week—to file its Reply Brief. This motion is not sought for delay only but
so that justice may be done.
2. Furthermore, Mr. Russell, counsel for Appellant and chief brief-writer,
needs additional time to prepare the Reply Brief in light of being chief brief-writer in
Cause No. 15-20213; Evanston Insurance Company vs. Lapolla Industries, Inc.; in the
U.S. Court of Appeals for the 5th Circuit, which said brief is also currently due on July
13, 2015.
CERTIFICATE OF CONFERENCE
Counsel for Appellant has contacted counsel for Appellees regarding this
motion, and Appellees’ counsel, has indicated that they are not opposed to this Motion
for Extension.
WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully prays
that the Court grant its Motion for Extension of Time to File Reply Brief and extend
171327-00331 DBR 7/7/2015 00979216.WPD 1 -2-
the time for it to file Appellant’s Reply Brief on the Merits through, and including,
July 17, 2015.
Respectfully submitted,
HOOVER SLOVACEK LLP
By: /s/ Dylan B. Russell
DYLAN B. RUSSELL
State Bar No. 24041839
Galleria Tower II
5051 Westheimer, Suite 1200
Houston, Texas 77056
Telephone: 713-977-8686
Facsimile: 713-977-5395
russell@hooverslovacek.com
ATTORNEYS FOR APPELLANT,
INWOOD FOREST COMMUNITY
IMPROVEMENT ASSOCIATION
CERTIFICATE OF SERVICE
I hereby certify that on this, the 7th day of July, 2015, a true and correct copy
of the foregoing document was served in accordance with the Rules to all counsel of
record and/or pro se parties, if any.
/s/ Dylan B. Russell
Dylan B. Russell
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