Elbert Davis v. Ebbie Loving D/B/A A-K-A Bail Bonds

Opinion

ACCEPTED 14-15-00059-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 9/21/2015 12:00:00 AM CHRISTOPHER PRINE CLERK

NO. 14-15-00059-CV

IN THE FILED IN 14th COURT OF APPEALS FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS AT HOUSTON, TEXAS 9/21/2015 12:52:00 PM CHRISTOPHER A. PRINE ELBERT DAVIS, Clerk Appellant,

V.

EBBIE LOVING d/b/a A-K-A BAIL BONDS, Appellee

APPELLEE’S MOTION FOR LEAVE TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW Appellee, Ebbie Loving d/b/a A-K-A Bail Bonds and requests

additional time to file its brief pursuant to TRAP 10.5(b) and shows as follows:

1. Appellee’s brief was is due on September 21, 2015

2. Appellee requests an additional seven (7) days to file her brief. This extension

would be to September 28, 2015.

3. This is Appellee’s first request for leave to extend time to file her brief.

4. Appellee requests more time because appellee’s attorney requires time to

obtain and finalize the brief. Appellee’s attorney experienced a death in his

family this month that required travel and time away from his office. This

event also unfortunately coincided with appellee’s assistant’s educational leave. These events left appellee’s attorney short staffed temporarily, and

resulted in backlog in appellee’s attorney’s calendar.

5. Appellee respectfully requests the she be given leave to extend time to file her

brief in this cause to September 28, 2015.

Respectfully Submitted,

/s/ Eddie L. Gomez _____________________ Eddie L. Gomez TBN 24055562 Eddie Gomez, P.C. Great Southwest Building 1314 Texas Avenue, Suite #1500 Houston, Texas 77002 Tel: (713) 653-3867 Attorney for Appellee

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was

served on the 20th day of September, 2015, by electronic service as follows:

Kurt G. Clarke Attorney for Appellant SBN: 04316720 6200 Savoy Drive, Ste 458 Houston, Texas 77036 (713) 779-5500 (713) 779-6668 – fax kgclaw@aol.com /s/ Eddie L. Gomez ________________________ Eddie L. Gomez