Patrick O'Connor & Associates, LP v. Chester R. Hall ( 2015 )

ACCEPTED
01-15-00661-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/2/2015 3:11:56 PM
CHRISTOPHER PRINE
CLERK
01-15-00661-CV
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURT OF APPEALS 11/2/2015 3:11:56 PM
CHRISTOPHER A. PRINE
FOR THE FIRST DISTRICT OF TEXS AT HOUSTON
Clerk
PATRICK O'CONNOR & ASSOCIATES, L.P.
Appellant
v.
CHESTER R. HALL
Appellee
FIRST UNOPPOSED MOTION FOR EXTENTISION OF TIME TO FILE
APPELLANT'S BRIEF
Appeal from Cause No. 1036533, In the County Court at Law No. 4, Harris County,
Texas
THE LAW OFFICES OF VEKENO KENNEDY THE SIDDIQUI LAW FIRM
Vekeno Kennedy Saif A. Siddiqui
Texas Bar No. 24077118 Texas Bar No. 24052305
3346 E. T.C. Jester Blvd., Suite F-27 3346 E. T.C. Jester, Suite F-11
Houston, Texas 77018 Houston, Texas 77018
Phone:(713) 375-4230 Tel: (713) 927-2775
Fax: (713) 457-2954 Fax: (832) 787-1284
kennedy.re.law@gmail.com ss@siddiquilaw.com
ATTORNEYS FOR APPELLANT
1
TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant, Patrick
O'Connor & Associates, L.P. files this Unopposed Second Motion to Extend Time
to File Appellant's Brief.
Appellant's opening brief is currently due on November 2, 2015.
Counsel for Appellant requests a 10-day extension of time to file its brief,
making the brief due on November 12, 2015. This is the second request for
extension of time to file the opening brief.
Counsel for Appellant relies on the following reasons, in addition to the
routine matters that counsel must attend to in daily practice, to explain the need for
the requested extension:
Counsel for Appellant was unable to obtain a copy of the reporter' s
transcript with sufficient time to complete Appellant's Brief, as the Court Reporter
responsible for its preparation could not be located in a timely manner.
Counsel for Appellant seeks this extension of time to be able to prepare a
cogent and succinct brief to aid this Court in its analysis of the issues presented.
This request is not sought for delay but so that justice may be done.
The undersigned has conferred with opposing counsel, and he has indicated
that his client does not oppose this motion.
All facts recited in this motion are within the personal knowledge of the
counsel signing this motion, therefore no verification is necessary under Rule of
Appellate Procedure 10.2.
2
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this
Unopposed First Motion to Extend Time to File Appellant's Brief and extend the
Deadline for Filing the Appellant's Brief up to and including November 12, 2015,
and grant Appellant all other relief to which it may be entitled.
Respectfully submitted,
LAW OFFICE OF VEKENO KENNEDY
/ Vekeno Kennedy
Vekeno Kennedy
Texas Bar No. 24077118
3346 East T.C. Jester Blvd., Suite F-27
Houston, Texas 77018
Phone:(713) 375-4230
Fax: (713) 457-2954
kennedy.re.law@gmail.com
ISa if Siddiqui
Saif A. Siddiqui
The Siddiqui Law Firm
Texas Bar No. 24052305
3346 E. T.C. Jester, Suite F-11
Houston, Texas 77018
Tel : (713) 927-2775
Fax: (713) 457-2961
ss@siddiquilaw.com
ATTORNEYS FOR APPELLANT
3
CERTIFICATE OF CONFERENCE
I certifY that I conferred with counsel for Appellee regarding this motion
and that Appellee is not opposed to this motion.
CERTIFICATE OF SERVICE
I hereby certify Pursuant to Rule 21a that on this the 2nd day of November, 2015 a true and
correct copy of the foregoing was forwarded by facsimile transmission, regular mail,
certified mail, return receipt requested, hand-delivery, and/or by any other method as
agreed between the parties to the following:
Mr. Paul Pilibosian via electronic mail
Hoover Slovacek, LLP
5847 San Felipe, Suite 2200
Houston, Texas 77057
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