Elizabeth M. Trammell v. Fletcher v. Trammell, Sr.

• Court: Court of Appeals of Texas
• Decided: January 5, 2015
• Docket: 01-14-00629-CV
• Status: Published

Opinion

ACCEPTED 01-14-00629-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 1/5/2015 12:11:30 PM CHRISTOPHER PRINE CLERK

NO: 01-14-00629-CV

FILED IN 1st COURT OF APPEALS IN THE HOUSTON, TEXAS FIRST DISTRICT COURT OF APPEALS OF 1/5/2015 12:11:30 PM TEXAS AT HOUSTON, TEXAS CHRISTOPHER A. PRINE Clerk

ELIZABETH M. TRAMMELL, Appellant v. FLETCHER V. TRAMMELL, SR. Appellee

from the 308 th Judicial District Court of Harris County, Texas, The Honorable James Lombardino Presiding Trial Court Case No. 2010-72050

APPELLANT'S UNOPPOSED MOTION TO EXTEND BRIEFING DEADLINE

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW, Appellant Elizabeth M. Trannnell and files her Unopposed

Motion to Extend Briefing Deadline by 1 week and in support hereof, would show

this Honorable Court as follows:

I.

Appellant brings this motion pursuant to Texas Rules of Appellate Procedure

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Page 1 of 3 38.6(d) and in compliance with Rule 10.5(b).

II.

The deadline for Appellant to file her brief is January 5, 2015. Appellant

requests a 1 week extension of her briefing deadline malting the deadline for filing

Appellant's Brief on January 12,2015.

III.

Appellant does not seek this extension for the purposes ofdelay. Lead counsel

for Appellant, Maurice Bresenhan Jr., has had an unexpectedly full December docket,

with numerous court hearings and a number of cases in process.

IV.

This is the second extension requested by Appellant. Maurice Bresenhan Jr.

hereby certifies that he or a member of his firm has conferred with Appellee's lead

counsel on appeal, Sallee S. Smyth, and Appellee is not opposed to the Court's

granting of this motion.

PREMISES CONSIDERED, Appellant Elizabeth M. Trammell respectfully

requests that the Court grant an extension of 1 week for the filing of the Appellant's

brief making the extended deadline January 12, 2015 the date Appellant's Brief is

due.

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Page 2 of 3 Respectfully submitted,

ZUKOWSKI, BRESENHAN, SINEX & PETRY, LLP

lsi Maurice Bresenhan. Jr Maurice Bresenhan, Jr. State Bar Number 02959000 11 77 West Loop South, Suite 1100 "Houston, Texas 77027 713/965-9969; 713/963-9169 Facsimile mbresenhan@zbsplaw,com Counsel for Appellant, Elizabeth M, Trammell

CERTIFICATE OF CONFERENCE

I do hereby certify that on January 5, 2015, I have conferred with Appellee's counsel regarding Appellant's request for extension of the deadline for Appellant's Brief and Appellee's counsel indicated to me that Appellee is unopposed to Appellant's request.

lsi Cynthia Keen Perlman Cynthia Keen Perlman

CERTIFICATE OF SERVICE

As required by Texas Rule ofAppellate Procedure 6.3 and 9,5(b), (d), and (e), I certify that I have served this document on all other parties, as listed below, on January 5,2015, as follows:

VIA FAX (281) 238-6202 and EMAIL Sallee S. Smyth 800 Jackson Street Richmond, Texas 77469 Counsel for Fletcher V. Trammell, SI. lsi Maurice Bresenhan, Jr Maurice Bresenhan JI.

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