in the Estate of Mary E. Larson ( 2017 )

ACCEPTED
14-16-00587-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
12/22/2017 3:35 PM
CHRISTOPHER PRINE
CLERK
No. 14-16-00587-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE FOURTEENTH HOUSTON,
DISTRICT TEXAS
12/22/2017 3:35:13 PM
OF TEXAS AT HOUSTON
CHRISTOPHER A. PRINE
Clerk
DEBBI RATZ, GWEN PATTERSON, AND WENDY BRUNEY, INDIVIDUALS,
Appellants,
v.
CATHERINE N. WYLIE, WILLIAM T. POWELL, INDIVIDUALS AND ROBERT LARSON, AS
INDEPENDENT EXECUTOR OF THE ESTATE OF GEORGE N. LARSON, JR., DECEASED,
Appellees.
On Appeal from the Probate Court of Galveston County, Texas
Trial Court Cause No. PR-0075669
APPELLEES’ MOTION FOR EXTENSION OF TIME
TO FILE MOTION FOR REHEARING
TO THE HONORABLE COURT OF APPEALS:
Appellees respectfully ask this Court to extend the deadline for filing their
motion for rehearing by 30 days, to January 22, 2018. This is the first request for an
extension of time to file this motion.
1. Appellees’ motion for rehearing is due on Friday, December 22, 2017.
2. Appellees’ counsel has devoted time to the preparation of their motion
for rehearing, and has engaged additional counsel to assist in its preparation. Its
completion has been delayed, however, by the following circumstances and
conflicts:
a. Drafting and revising a response, filed December 14, to an
emergency motion for contempt in an adversary case in a
bankruptcy matter in the Southern District of Texas.
b. Year-end settlement negotiations in various trial and appellate
court matters during the week of December 18, 2017, including
a mediation in Hidalgo County ordered by the trial court to occur
on or before December 22, 2017.
c. Scheduling conflicts associated with preparation for the
Christmas and New Year holidays.
d. The Christmas and New year holidays. The undersigned
counsel’s office is closed the afternoon of December 22,
December 25 and 26, and January 1, 2018. The undersigned
counsel is also traveling with his family on December 26, 27, and
28, to meet other family members in the Waco area to share in
Christmas celebrations.
e. No other obligation has taken precedence over the brief in this
case. Counsel has worked and will work with other lawyers to
fulfill these responsibilities. The delay in completing this brief
has been unavoidable.
3. This request is not made for purposes of delay, but in the interest of
justice. This is the first request for an extension of time regarding this motion.
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PRAYER
For these reasons, Appellees respectfully request that this Court extend the
deadline for their motion for rehearing by 30 days, to January 22, 2018, and grant
all other relief to which they may be justly entitled.
Respectfully submitted,
William T. Powell
State Bar No. 16206800
244 Malone
Houston, Texas 77007
713-722-9233 - telephone
713-722-9433 - facsimile
Email: ted@tedpowelllaw.com
Catherine N. Wylie
The Wylie Law Firm
State Bar No. 24033479
2211 Norfolk Street, Suite 440
Houston, Texas 77098
Email: cwylie@wylielawfirm.com
713-275-8230 - telephone
713-275-8239 – facsimile
/s/ Jeff Nobles
Jeff Nobles
jeff@appealsplus.com
State Bar No. 15053050
SMITH LAW GROUP, LLLP
3700 Buffalo Speedway, Suite 520
Houston, Texas 77098
Telephone: (713) 489-1688
Telecopier: (713) 277-7220
ATTORNEYS FOR APPELLEES
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CERTIFICATE OF CONFERENCE
We have conferred with opposing counsel, and this motion is opposed.
/s/ Jeff Nobles
Jeff Nobles
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been sent
via e-filing or facsimile to the following counsel on December 22, 2017:
Rudolph M. Culp
Horrigan & Goehrs, L.L.P.
5020 Montrose, Suite 500
Houston, Texas 77006
/s/ Jeff Nobles
Jeff Nobles
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