Levent Ulusal v. Lentz Engineering, L C ( 2015 )

ACCEPTED
01-15-00597-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/2/2015 11:25:43 PM
CHRISTOPHER PRINE
CLERK
01-15-00597-CV
IN THE COURT OF APPEALS FILED IN
1st COURT OF APPEALS
FOR THE FIRST COURT OF APPEALS DISTRICTHOUSTON, TEXAS
HOUSTON, TEXAS 12/2/2015 11:25:43 PM
CHRISTOPHER A. PRINE
Clerk
LEVENT ULUSAL,
Appellant,
V.
LENTZ ENGINEERING, L C
Appellee.
MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF
Daniel Kistler
Daniel Kistler, Attorney at Law
Office Address:
17041 El Camino Real
Ste. 204
Houston, Texas 77058
Mailing Address:
2617C West Holcombe
No. 421
Houston, Texas 77025
Telephone: (713) 855-0827
Facsimile: (866) 352-5124
kistlerattorney@comcast.net
ATTORNEY FOR APPELLANT
MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF
Comes now, Ulusal Levent, Appellant herein, and files this his first
Motion for Extension of Time to File Reply Brief, and in support would
show the following:
1. Appellee Lentz Construction, L.C. filed its Brief on November
12, 2015. Pursuant to Rule 38.6(c), Tex. R. App. P., the deadline for filing
Appellant’s Reply Brief is December 2, 2015.
2. Appellant seeks an additional fourteen (14) days, or until
December 16, 2015, in which to file its Reply Brief.
3. Appellant’s counsel has been delayed in the preparation and
finalization of this brief due to trial commitments in Cause No. 2014-43377;
Christopher Stanzel, et al, v. John Hinkle, pending in the 190th Judicial
District Court of Harris County, Texas, which is presently set for trial on
December 7, 2015; Cause No. 2014-15521; Harris County, et al v. L V
Thompson, 55th Judicial District Court of Harris County, Texas, which is
presently set for trial on December 9, 2015, and Cause No. 2014-39578;
Harris County, et al v. Ramona Jones, et al; which was set for trial on
December 1, 2015, and not continued from that setting until the trial date.
4. Appellant’s counsel believed that he would be able to complete
this Reply Brief, despite the time required for trial preparations in the cases
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cited above, other matters which required his attention during the last 20
days, and the Thanksgiving Holiday. However, it has become apparent that
Appellant will require additional time in which to complete his Brief.
Appellant reasonably requires an additional fourteen (14) days in which to
complete and file his Brief.
5. This is the first motion for an extension of time to file
Appellant’s Reply Brief.
CERTIFICATE OF CONFERENCE
6. Due to the late hour in filing this Motion, Appellant’ counsel is
not able to contact counsel for the Appellee, Lentz Engineering, L.C.
Appellant’s counsel shall apprise the court as soon as possible on whether
Appellee has any objection to the relief requested.
Wherefore, premises considered, Appellant Levant Ulusal hereby
requests that the court grant a fourteen (14) day extension of time for
Appellant to file his Reply Brief, and for all other and further relief, at law
and in equity, to which Appellant may be justly entitled.
Respectfully submitted,
/s/Daniel Kistler
Daniel Kistler, Attorney at Law
Office Address:
17041 El Camino Real
Ste. 204
2
Houston, Texas 77058
Mailing Address:
2617C West Holcombe
No. 421
Houston, Texas 77025
Telephone: (713) 855-0827
Facsimile: (866) 352-5124
kistlerattorney@comcast.net
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
On this 2nd day of December, 2015, a true and correct copy of
the foregoing Motion for Extension of Time to File Reply Brief of
Appellant Levant Ulusal was served on all counsel of record and
pro se parties by certified mail, return receipt requested, facsimile
transmission, electronic transmission and/or hand delivery.
Timothy R. Ploch via facsimile: (713) 862-7575 and
Linda M. Talbot email: lawplochstaff@flash.net
Timothy R. Ploch, P.C.
730 N. Post Oak Rd., Ste 100
Houston, Texas 77024
Keith Livesay
Livesay Law Office
Brazos Suites No. 9
McAllen, TX. 78504
Via email to: RGVAppellateLaw@yandex.com
/s/ Daniel Kistler
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