Deana A. Pollard Sacks v. Thomas F. Hall and Thomas F. Hall, D.D.S., M.S. P.A.
This text of Deana A. Pollard Sacks v. Thomas F. Hall and Thomas F. Hall, D.D.S., M.S. P.A. (Deana A. Pollard Sacks v. Thomas F. Hall and Thomas F. Hall, D.D.S., M.S. P.A.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
ACCEPTED 01-14-00301-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 1/6/2015 2:33:07 PM CHRISTOPHER PRINE CLERK
NO. 01-14-00301-CV
IN THE FIRST COURT OF APPEALS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 1/6/2015 2:33:07 PM CHRISTOPHER A. PRINE Clerk DEANA POLLARD SACKS, APPELLANT vs. THOMAS F. HALL AND THOMAS F. HALL, D.D.S., M.S., P.A., APPELLEES
From the County Court at Law No. 3 of Harris County, Texas Trial Court Cause No. 919405
APPELLANT’S MOTION FOR AN EXTENSION OF TIME TO FILE REPLY BRIEF
TO THE HONORABLE JUSTICES OF THE COURT:
Comes now Appellant, Deana Pollard Sacks, who respectfully moves for an
extension of time in which to file her reply brief and in support would respectfully show
as follows:
A. Introduction
1. Appellant is Deana Pollard Sacks.
2. Appellees are Thomas F. Hall and Thomas F. Hall, D.D.S., M.S., P.A.
B. Argument and Authorities
3. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to
Page 1 extend the time to file the brief.
4. Movant received Appellee’s Brief on December 22, 2014. Movant’s reply brief
is currently due on January 9, 2015. Movant seeks an extension of 20 days. No previous
extensions have been requested for this reply brief.
5. Movant’s counsels’ schedules have not allowed time to properly prepare
Appellant’s reply brief due to several pending matters which included a planned family
holiday vacation over Christmas and New Years, preparation for critical client
depositions in a U.S. Federal court case out of the Western District of Texas, Austin
Division, and co-counsel’s reply brief due in the Texas Supreme Court in Nations v.
Heitkamp. Movant’s counsel and co-counsel have been involved in daily preparations for
these matters, along with their normal caseload.
C. Conclusion
6. Deana Pollard Sacks, Appellant in this matter, requests the Court grant an
extension of the deadline to file her reply brief until January 29, 2015. This request is not
sought for delay, but so that justice may be done. The matters contained in this motion
are within my personal knowledge and do not require separate verification.
D. Prayer
7. For these reasons, Deana Pollard Sacks, Appellant, asks the Court to grant an
extension of time to file her reply brief until January 29, 2015.
Page 2 Respectfully submitted,
/s/ Brad Beers Brad Beers SBOT: 02041400 5020 Montrose Blvd., Suite 700 Houston, Texas 77006 713-654-0700 713-654-9898 facsimile BBeers@BeersLaw.net Counsel for Deana Pollard Sacks
Certificate of Conference I certify that I attempted to communicate with counsel for appellees, Gregory Travis and John Woods, over the holidays and have not heard back from them.
/s/ Brad Beers Brad Beers
Certificate of Service Pursuant to Texas Rules of Appellate Procedure 6.3 and 9.5(b), (d), and (e), I certify that on January 6, 2015, a copy of this motion was mailed via facsimile service as follows:
Gregory Travis Via Facsimile 713-626-3801 John Woods The Travis Law Firm 800 Wilcrest Drive, Suite 350 Houston, Texas 77042
Page 3
Free access — add to your briefcase to read the full text and ask questions with AI
Cite This Page — Counsel Stack
Deana A. Pollard Sacks v. Thomas F. Hall and Thomas F. Hall, D.D.S., M.S. P.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/deana-a-pollard-sacks-v-thomas-f-hall-and-thomas-f-hall-dds-ms-texapp-2015.