Loren Rose Jeremy v. Nicholas Dusan Jeremy ( 2015 )

ACCEPTED
14-15-00279-cv
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/16/2015 8:47:53 PM
CHRISTOPHER PRINE
CLERK
CASE NO. 14-15-00279-CV
LOREN ROSE JEREMY, § IN THE FOURTEENTH
FILED IN
14th COURT OF APPEALS
§ HOUSTON, TEXAS
Appellant, § 11/16/2015 8:47:53 PM
§ CHRISTOPHER A. PRINE
v. § Clerk
COURT OF APPEALS
§
NICHOLAS DUSAN JEREMY, et al., §
§
Appellees. § HOUSTON, TEXAS
APPELLANT’S MOTION TO EXTEND TIME TO FILE THE BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Appellant asks the Court to extend the time to file his brief.
INTRODUCTION
1. Appellant is Loren Rose Jeremy; appellees are Nicholas Dusan Jeremy
and Theresa Henry.
2. No rule limits the time within which to file this motion to extend time.
See TEX. R. APP. P. 38.6(d).
ARGUMENT & AUTHORITIES
3. The Court has the authority under Texas Rule of Appellate Procedure
38.6(d) to extend the time to file the brief.
4. The Appellant’s brief was due on September 30, 2015.
5. Appellant requests an additional sixty days to file her brief, extending
the time until November 30, 2015.
6. No extension has been granted to extend the time to file Appellant’s
brief.
7. Appellant needs additional time to file her brief because she has been
hospitalized with a severe gastrointestinal condition which has required multiple
surgeries and for which she is finally recovering. Appellant has been unable to assist
her counsel in this appeal for the past two (2) months, only recently being well
enough to confer. Appellant has one additional medical procedure planned in the
next two weeks, but after that should be able to fully assist her counsel in prosecuting
her appeal.
CONCLUSION
8. The Court has the authority under Texas Rule of Appellate Procedure
38.6(d) to extend the time to file the brief. Appellant requests an additional sixty
days to file her brief, extending the time until , because Appellant has been extremely
ill these past few months and only now is able to assist counsel in the prosecution of
this appeal.
PRAYER
9. For these reasons, Appellant asks the Court to grant an extension of
time to file her brief until November 30, 2015.
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Respectfully submitted,
By: __/s/ Mark Aronowitz____________
MARK ARONOWITZ
State Bar No.: 00793281
Attorney for Loren Rose Jeremy
P.O. Box 1201
Texas City, TX 77592-1201
Tel: (281) 402-6780
Fax: (281) 715-4284
CERTIFICATE OF COMPLIANCE
I certify that I have complied with Rule 12 of the Texas Rules of Appellate
Procedure because this motion is only 423 words.
_____/s/ Mark Aronowitz____________
MARK ARONOWITZ
CERTIFICATE OF SERVICE
I certify that a copy of the Appellant’s Motion to Extend Time to File the Brief
was served on all parties through their counsel of record by a method permitted by
Texas Rule of Appellate Procedure 9.5 on November 17, 2015.
_____/s/ Mark Aronowitz____________
MARK ARONOWITZ
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