Michael Queen and Ian Magee v. RBG USA, Inc. ( 2015 )

ACCEPTED 14-14-00829-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/6/2015 3:09:04 PM CHRISTOPHER PRINE CLERK No. 14-14-00829-CV FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS IN THE COURT OF APPEALS FOR THE 7/6/2015 3:09:04 PM CHRISTOPHER A. PRINE FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS Clerk HOUSTON, TEXAS MICHAEL QUEEN and IAN MAGEE, Appellants/Cross Appellees, v. RBG USA, Inc., Appellee/Cross Appellant. On appeal from the 268th Judicial District Court of Fort Bend County, Texas JOINT MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE AND REPLY BRIEFS TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: Appellants Michael Queen and Ian Magee (collectively, “Appellants”) and Appellee RBG USA, Inc. (“Appellee”) (Appellants and Appellee are collectively referred to as the “Parties”), in the above-styled and numbered cause, file this Joint Motion for Extension of Time to File Responsive and Reply Briefs and request that the Court enter an order extending the time for the filing of their Responsive Briefs with the Court through, and including June 15, 2015, and for the filing of their Reply Briefs, if any, with the Court through, and including August 4, 2015, and in support thereof would respectfully show the following: 1. The Parties’ current deadline to file their Responsive Briefs is July 8, 2015. 2. The Parties’ current deadline to file their Reply Briefs, if any, is July 28, 2015. 3. The Parties’ counsels need additional time to prepare their Responsive and Reply Briefs because of their professional and personal schedules. 4. This is the Parties’ first request for an extension of time to file their Responsive and Reply Briefs. This motion is not sought for delay but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, the Parties respectfully pray that the Court grant their Joint Motion for Extension of Time to File Responsive and Reply Briefs and extend the time for them to file their Responsive Briefs through, and including, July 15, 2015, and extend the time for them to their Reply Briefs, if any, through, and including August 4, 2015. [signatures on following page] Respectfully submitted, /s/ Stephen J. Schechter1 /s/ Michael R. Rahmn Stephen J. Schechter Craig D. Dillard State Bar No. 17735512 State Bar No. 24040808 STEPHEN J. SCHECHTER, P.C. Michael R. Rahmn P.O. Box 792 State Bar No. 24074924 Boerne, Texas 78006 GARDERE WYNNE SEWELL LLP Telephone: (830) 249-3500 1000 Louisiana, Suite 3400 Facsimile: (830) 249-8500 Houston, Texas 77002-5007 stephen@sjs-pc-law.com Telephone: (713) 276-5500 Facsimile: (713) 276-5555 ATTORNEY-IN-CHARGE FOR cdillard@gardere.com APPELLANTS MICHAEL QUEEN mrahmn@gardere.com AND IAN MAGEE ATTORNEYS FOR APPELLEE RBG USA, INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Joint Motion for Extension of Time to File Briefs has been served on Appellants’ attorney of record on July 6, 2015. /s/ Michael R. Rahmn Michael R. Rahmn 1 With permission 6777000v.1