John W. Hankins v. Sarah T. Harris ( 2015 )

ACCEPTED
01-15-00396-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/23/2015 2:30:50 PM
CHRISTOPHER PRINE
CLERK
CASE NO. 01-15-00396-CV
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE FIRST COURT OF APPEALS
11/23/2015 2:30:50 PM
HOUSTON, TEXAS CHRISTOPHER A. PRINE
_______________________________________ Clerk
John W. Hankins
v.
Sarah T. Harris
_______________________________________
On Appeal from the 333rd Judicial District Court
of Harris County, Texas
Trial Court Case No. 2014–01360
_______________________________________
APPELLANT’S FIRST UNOPPOSED
MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF
TO THE HONORABLE COURT OF APPEALS:
Appellant, John W. Hankins requests a 7–day extension to file his
reply brief and for good cause, would show as follows:
1. Hankins’ reply brief is due on November 23, 2015.
2. This is Hankins’ first motion for extension of time to file his reply
brief.
3. Hankins respectfully requests a 7–day extension to file his reply brief
so that the undersigned can adequately prepare the same.
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4. The undersigned’s litigation docket during the last two weeks has
prevented him from completing Hankins’ reply brief in this case.
Specifically, the undersigned:
 Prepared and filed a brief on the merits with the Supreme Court
of Texas on November 12, 2015, in the case–styled and
numbered, Ex parte Norman Crittenden, Case No. 15–0184.
 Prepared and filed a brief on the merits with the Supreme Court
of Texas on November 12, 2015, in the case–styled and
numbered, McLean v. Livingston, Case No. 15–0100.
 Prepared and filed a reply brief on the merits with the Supreme
Court of Texas on November 12, 2015, in the case–styled and
numbered, Steve Bumpas Custom Homes, Inc. v. Chris
Wallace, et al, Case No. 15–0321.
 Prepared and filed a motion for rehearing with the Supreme
Court of Texas on November 10, 2015, in the case–styled and
numbered, Worldwide Clinical Trials v. Arnold, Case No. 14–
0786.
 Prepared and prosecuted a jury trial on November 18, 2015.
 Prepared and presented a CLE seminar in El Paso on November
19, 2015.
5. Also, the undersigned’s grandmother passed away last week. The
undersigned attended her funeral on November 20, 2015, which caused
him to be out of the office.
6. Also, the undersigned had various meetings, prepared motions and
briefs to be filed in other cases, prepared responses to motions, attended
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hearings, and conducted activities usually associated with a litigation
practice in the last two weeks.
7. As such, the undersigned has not had sufficient time to prepare the
reply brief in this case.
8. Pursuant to TEX. R. APP. P. 10.3, the undersigned conferred with
counsel for the Appellee, and counsel is unopposed to this motion.
FOR THESE REASONS, Appellant prays that this Honorable Court
grant this motion for extension of time and extend the deadline for filing
his reply brief to November 30, 2015, and requests all other relief to which
he may be entitled.
Respectfully submitted,
LEYH, PAYNE & MALLIA, PLLC
By: /s/ Sean M. Reagan
Sean Michael Reagan
sreagan@lpmfirm.com
Texas Bar No. 24046689
9545 Katy Freeway, Suite 200
Houston, Texas 77024
Telephone: 713-785-0881
Facsimile: 713-784-0884
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
I certify that a true and correct copy of this document has been served
to all interested parties of record on November 23, 2015 as follows:
Brian B. Kilpatrick Via Email
H. Fred Cook Via Email
Wilson, Cribbs & Goren, P.C.
2500 Fannin Street
Houston, Texas 77002
Jarrett L. Ellzey Via Email
W. Craft Hughes Via Email
Hughes Ellzey, L.L.P.
2700 Post Oak Blvd., Suite 1120
Galleria Tower I
Houston, Texas 77056
Hartley Hampton Via Email
Hampton & King
3 Riverway, Suite 910
Houston, Texas 77056
William Feldman Via Email
Michael J. Mazzone Via Email
Michael T. Powell Via Email
Robert Carlton Via Email
Haynes & Boone, LLP
1221 McKinney Street, Suite 2100
Houston, Texas 77010-2007
/s/ Sean M. Reagan
Sean M. Reagan
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