Frank M. Seliger v. Ethiopian Evangelical Church

Opinion

ACCEPTED

03-14-00621-CV

4848160

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/10/2015 3:09:40 PM

JEFFREY D. KYLE

CLERK

NO. 03-14-00621CV

FILED IN

3rd COURT OF APPEALS

IN THE COURT OF APPEALS AUSTIN, TEXAS 4/10/2015 3:09:40 PM

THE 1HlRD DISTRICT OF 1EXAS JEFFREY D. KYLE

AUSTIN, 1EXAS Clerk

FRANK SELIGER,

Appellant

v.

THE ETHIOPIAN EVANGELICAL CHURCH, Appellee.

Appeal from the County Court at Law Number One Travis County, Texas

Trial Court Case No. C-1-CV-14-005819 Hon. David Phillips, presiding

APPELLEE'S MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF

TO THE HONORABLE COURT OF APPEALS:

COMES NOW APPELLEE, ETHIOPIAN EVANGELICAL CHURCH, who files

this Motion for Extension of Time to File its Appeal Brief and respectfully shows

the following:

1. Appellee's deadline to file its Appeal Brief is April 10, 2015.

Appellee's Motion for Extension of Time to File Appellee's Brief Page 1 2. Part of the practice of Appellee's counsel involves a foreclosure prevention

program. Due to the large volume of client facing foreclosure during the

month of April, 2015, counsel for Appellee is in need of additional time to

complete and file the Appellee's Appeal Brief.

3. Appellee requests a two-week extension of time on which to file its Appeal

Brief to April24, 2015.

WHEREFORE, PREMISES CONSIDERED, Appellee prays this Court grant its

Motion for Extension of Time to File its Appeal Brief and extend its deadline to

file same to April 24, 20 15.

Respectfully submitted, By: Is/ James Minerve

James Minerve State Bar No. 24008692 115 Saddle Blanket Trail Buda, Texas 78610 (210) 336-5867 (888) 230-6397 (Fax) Attorney for Appellee

CERTIFICATE OF CONFERENCE

On April 09, 2015, the undersigned counsel for Appellee conferred with pro se Appellant, Fran Seliger, concerning the foregoing Motion and Mr. Seliger stated that he is not opposed to this Motion. See Exhibit A.

I sf James Minerve

James Minerve

Appellee's Motion for Extension of Time to File Appellee's Brief Page 2

CERTIFICATE OF SERVICE

I hereby certify that on this 1Oth day of April, 2015 a true and correct copy of the above and foregoing document was sent via Efile.txcourts.gov electronic filing notification system and via e-mail to the parties of record listed below:

Appellant Pro Se: Frank Seliger 21 08 East Yager Lane Austin, Texas 78754 E-mail: digitalfranks@att.net

I sf James Minerve

James Minerve

Appellee's Motion for Extension of Time to File Appellee's Brief Page 3

-- -- - - ·- -

EXHIBIT A

Maria Rogers

From: Frank Seliger <digitalfranks@att.net> Sent: Thursday, April 9, 2015 12:20 PM To: Maria Rogers Subject: RE: (Ethiopian Church/Seliger) REQUEST FOR EXTENSION TO FILE APPEAL BRIEF ON BEHALF OF ETHIOPIAN CHURCH

Hi Maria.

No probiem on th e extension. You a!! were very nice about my Appeliant's Brief extension ... so I will gladly do the same for you. If you need more t ime than the t wo weeks ... just let me know.

Helping people with foreclosure problems is important work. Good luck in vour efforts.

Yours sincerely,

Frank Seliger

From: Maria Rogers [mailto:mr@minervelaw.com] Sent: Thursday, April9, 2015 9:35AM To: digitalfranks@att.net Cc: Kevin Gates; James Minerve; James Minerve Subject: (Ethiopian Church/Seliger) REQUEST FOR EXTENSION TO FILE APPEAL BRIEF ON BEHALF OF ETHIOPIAN CHURCH Importance: High

Mr. Seliger: Our deadline to file the appeal brief for our client is this Friday, April lOth. Due to the large volume of clients we had this past Tuesday facing foreclosure on that day, we had to shift gears and work towards stopping the foreclosures for these clients and we now need additional time to complete and file our appeal brief. We are requesting your agreement to a two week extension oftime to file our brief. That would put our deadline to Friday, April 24th. We agreed to your request for extension of time to file in this case and we hope that you will reciprocate. Thank you in advance for your courtesy.

Sincerely, Maria Rogers Legal Assistant

The Minerve Law Firm 115 Saddle Blanket Trail Buda, Texas 78610 Tel: 888-819-1440 Ext. 102 Fax: 888-230-6397 Ema-iJ: DJ.r.@~Kil~J:1©.r\:f~?:Yi~S:!21l Website: .c.:.c":~c.;..:.:.:..:~·: : :_o,,,...,-""~'~-'·'·"·'··""!'''··-'·c