Grady L. Muhammad A/K/A Grady L. Choice v. Plains Pipeline, L.P., a Texas Limited Partnership

Court of Appeals of Texas

Grady L. Muhammad A/K/A Grady L. Choice v. Plains Pipeline, L.P., a Texas Limited Partnership

DecidedJanuary 27, 2017

Docket12-16-00189-CV

StatusPublished

This text of Grady L. Muhammad A/K/A Grady L. Choice v. Plains Pipeline, L.P., a Texas Limited Partnership (Grady L. Muhammad A/K/A Grady L. Choice v. Plains Pipeline, L.P., a Texas Limited Partnership) 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.

Bluebook

Grady L. Muhammad A/K/A Grady L. Choice v. Plains Pipeline, L.P., a Texas Limited Partnership, (Tex. Ct. App. 2017).

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Opinion

MOTION TO IMMEDIATELY FILE BRIEF OUT OF TIME

IN THE TWELFTH COURT OF APPEALS OF THE STATE OF TEXAS FILED IN COURT OF APPEALS 12lhGourl o' Appeals District

Grady L. Muhammad ) a/k/a Grady L. Choice ) ) Plaintiff-Appellee ) ) Court of Appeals Case No.: 12-16-00189 ) VS. ) ) Plains Pipeline, L.P., ) A Limited Texas Partnership ) ) Defendant-Appellant )

1. Background. The appellee's briefwas due on December 20, 2016, and that day has passed. The appellee has asked for and received three priorextension oftime to fde brief. 2. Authority. Pursuant to Rule 26(b) 3. Reason. The appellee is a truck driver and the only family member now in a financial position to hire an attorney or find services that could aid him with this case. The appellee was not ableto hire an attorney and was on the road working and the assistance and his niece whom are helping him, was not able to receive mail from the court of the date to file was December 20, 2016 not December 21, 2016.

Because of this, appellee ask for permission to file the brief immediately

Respectfully submitted Grady L. Muhammad a/k/a Grady L. Choice 4939 CR 4317 Larue, Texas 75770 COURT OF APPEALS CASE NO.: 12-16-00189

REQUEST FOR ORAL ARGUMENT CERTIFICATE OF SERVICE

Court of Appeal Case Number 12-16-00189 CV

The undersigned hereby certifies that on Friday, January 27, 2017, a copy of the foregoing response was served on the following counsel for Plains Pipeline, L.P. Counsel for Respondent received Certificate of Service for The Brief, Motion to Immediately File Brief and Request for Oral Arguments via fax to 210-249-3201.

Ross Molina Oliveros, P.C. 4118 Pond Hill Road, Ste#100 San Antonio, Texas 78231

PURIFICATION REQUIRED IF SERVICE IS BY A PERSON OTHER THAN A PARTY OR PARTY'S ATTORNEY)

I declare under penalty ofperjury that the information in this Certificate ofConference is true and correct.

V- „. -,..•-. . (1 Signed on]Q2AVj^^l ,2l>ir] in JXfr^ct', County, Texas

// •// /V/ ' M Y Signature of Person Providing $0£fee ._ Printed Name: /W//f (Oh fee -, Tfc^rftgW' Address: SH/^l/^ *-f/7^7 '

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MOTION TO IMMEDIATELY FILE BRIEF OUT OF TIME

IN THE TWELFTH COURT OF APPEALS OF THE STATE OF TEXAS FILED IN COURT OF APPEALS 12lhGourl o' Appeals District

Grady L. Muhammad ) a/k/a Grady L. Choice ) ) Plaintiff-Appellee ) ) Court of Appeals Case No.: 12-16-00189 ) VS. ) ) Plains Pipeline, L.P., ) A Limited Texas Partnership ) ) Defendant-Appellant )

1. Background. The appellee's briefwas due on December 20, 2016, and that day has passed. The appellee has asked for and received three priorextension oftime to fde brief. 2. Authority. Pursuant to Rule 26(b) 3. Reason. The appellee is a truck driver and the only family member now in a financial position to hire an attorney or find services that could aid him with this case. The appellee was not ableto hire an attorney and was on the road working and the assistance and his niece whom are helping him, was not able to receive mail from the court of the date to file was December 20, 2016 not December 21, 2016.

Because of this, appellee ask for permission to file the brief immediately

Respectfully submitted Grady L. Muhammad a/k/a Grady L. Choice 4939 CR 4317 Larue, Texas 75770 COURT OF APPEALS CASE NO.: 12-16-00189

REQUEST FOR ORAL ARGUMENT CERTIFICATE OF SERVICE

Court of Appeal Case Number 12-16-00189 CV

The undersigned hereby certifies that on Friday, January 27, 2017, a copy of the foregoing response was served on the following counsel for Plains Pipeline, L.P. Counsel for Respondent received Certificate of Service for The Brief, Motion to Immediately File Brief and Request for Oral Arguments via fax to 210-249-3201.

Ross Molina Oliveros, P.C. 4118 Pond Hill Road, Ste#100 San Antonio, Texas 78231

PURIFICATION REQUIRED IF SERVICE IS BY A PERSON OTHER THAN A PARTY OR PARTY'S ATTORNEY)

I declare under penalty ofperjury that the information in this Certificate ofConference is true and correct.

V- „. -,..•-. . (1 Signed on]Q2AVj^^l ,2l>ir] in JXfr^ct', County, Texas

// •// /V/ ' M Y Signature of Person Providing $0£fee ._ Printed Name: /W//f (Oh fee -, Tfc^rftgW' Address: SH/^l/^ *-f/7^7 '

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Grady L. Muhammad A/K/A Grady L. Choice v. Plains Pipeline, L.P., a Texas Limited Partnership, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grady-l-muhammad-aka-grady-l-choice-v-plains-pipeline-lp-a-texas-texapp-2017.