Peter D. Tran, Nam Van Nguyen, the Kim Hoang and Tuyen Ngoc Bui, on Behalf of the Vietnamese Community of Houston & Vicinity, Inc. a Non-Profit Corporation v. Aloysius Duy-Hung Hoang, Teresa Ngoc-Bich Hoang, Cavatina Truong, Skybird Nguyen and Hoc Nhu Phan ( 2015 )

ACCEPTED
01-14-00973-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/4/2015 2:18:47 PM
CHRISTOPHER PRINE
CLERK
NO. 01-14-00973-CV
PETER D. TRAN, NAM VAN IN THE FIRST FILED IN
NGUYEN, THE KIM HOANG, 1st COURT OF APPEALS
HOUSTON, TEXAS
AND TUYEN NGOC BUI
5/4/2015 2:18:47 PM
ON BEHALF OF THE
CHRISTOPHER A. PRINE
VIETNAMESE COMMUNITY OF Clerk
HOUSTON & VICINITY, INC.,
Appellants,
VS. COURT OF APPEALS
ALOYSIUS DUY-HUNG HOANG,
TERESA NGOC-BICH HOANG,
CAVATINA TRUONG, SKYBIRD
NGUYEN AND HOC NHU PHAN,
Appellees. HOUSTON, TEXAS
APPELLANTS' MOTION TO EXTEND TIME TO FILE BRIEF
Appellants ask the Court to extend the time to file their brief.
A. Introduction
1. Appellants are Peter D. Tran, Nam Van Nguyen, The Kim Hoang, and Tuyen
Ngoc Bui on Behalf of the Vietnamese Community of Houston & Vicinity, Inc.
2. This Motion to Extend Time to File Brief is brought pursuant to Rule 10.5(b)
of the Texas Rules of Appellate Procedure.
B. Argument & Authorities
3. The Court has the authority under Texas Rule of Appellate Procedure 10.5(b)
to extend the time to file the brief.
4. Appellants request an additional 7 days to file their brief, extending the time
until May 11, 2015.
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5. Three previous extensions have been requested and granted to extend the time
to file Appellants' brief.
6. Appellants need additional time to file their brief because Appellants' counsel
has been involved in multiple state district court cases and mediations. Additionally,
Appellants' counsel lost his paralegal to another firm and has not found a suitable
replacement requiring counsel to undertake all legal work without assistance.
Appellants' counsel requires additional time to complete the drafting of the brief.
C. Conclusion
7. Appellants require additional time to complete their brief.
D. Prayer
8. For these reasons, Appellants ask the Court to grant an extension of time to
file their brief until May 11, 2015.
Respectfully submitted,
ALLAN A. CEASE & ASSOCIATES, P.C.
/s/ Allan A. Cease
BY: Allan A. Cease
Texas Bar No. 04040550
Email: allancease@comcast.net
56 Sugar Creek Center Blvd, Suite 300
Sugar Land, Texas 77478
Tel. 281-980-0909
Fax 281-980-1069
Attorney for Appellants, Peter D. Tran, Nam Van
Nguyen, The Kim Hoang, and Tuyen Ngoc Bui
on Behalf of the Vietnamese Community of
Houston & Vicinity, Inc.
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VERIFICATION
STATE OF TEXAS
FORT BEND COUNTY §
Before me, the undersigned notary, on this day personally appeared Allan A.
Cease, the affiant, a person whose identity is known to me. After I administered an
oath to affiant, affiant testified:
"My name is Allan A. Cease. I am capable of making this verification. I have
read the Appellants' Motion to Extend Time to File Brief. The facts stated in it are
within my personal knowledge and are true and correct."
Allan A. Cease
SWORN TO AND SUBSCRIBED BEFORE ME by Allan A. Cease on May 4,
2015.
,,,,,,,,,,
/6%*tt:s * %si Notary ANNIE NGUYEN
Public. State of Texas
:,,z My Commission Expires Notary Public - St. Texas
,;;,,POrW
' ,,,,,,,,,,, April 17, 2019
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CERTIFICATE OF CONFERENCE
I certify that I have conferred with Brent C. Perry and he is unopposed to this
motion.
/s/ Allan A. Cease
Allan A. Cease
CERTIFICATE OF SERVICE
I certify that a copy of Appellants' Motion to Extend Time to File Brief was
served on Appellees, Aloysius Duy-Hung Hoang, Teresa Ngoc-Bich Hoang, Cavatina
Truong, Skybird Nguyen and Hoc Nhu Phan, through counsel of record, Brent C.
Perry, at 800 Commerce Street, Suite 102, Houston, Texas 77002, by email to
brentperry@brentperrylaw.com, on May 4, 2015.
/s/ Allan A. Cease
Allan A. Cease