Guam Industrial Services, Inc. D/B/A Guam Shipyard v. Dresser-Rand Company

Opinion

ACCEPTED

01-15-00842-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS 11/12/2015 2:55:45 PM CHRISTOPHER PRINE

CLERK

NO. 01-15-00842-CV

FILED IN

IN THE COURT OF APPEALS FOR THE 1st COURT OF APPEALS HOUSTON, TEXAS

FIRST DISTRICT OF TEXAS

11/12/2015 2:55:45 PM CHRISTOPHER A. PRINE

Clerk

GUAM INDUSTRIAL SERVICES, INC., Appellant,

v.

DRESSER-RAND COMPANY,

Appellee.

ON APPEAL FROM THE 61ST JUDICIAL DISTRICT COURT HARRIS COUNTY, TEXAS TRIAL CAUSE NO. 2015-01910

UNOPPOSED MOTION FOR

EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

THE DIETRICH LAW FIRM Fred Dietrich State Bar 05857050 2211 Norfolk St., Suite 620 Houston, Texas 77098 Tel.: 713.830.7687 Fax: 713.893.6044 fdietrich@dietrich-law.com

ATTORNEY FOR APPELLANT GUAM INDUSTRIAL SERVICES, INC.

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TO THE HONORABLE FIRST COURT OF APPEALS:

Pursuant to Tex. R. App. P. 10.5(b), appellant Guam Industrial Services, Inc. moves

for an order extending the November 24, 2015 due date for its appellant’s brief to and

including December 23, 2015 (a 29 day extension). In support of its motion, appellant

respectfully offers the following:

1. Appellant’s brief is due on November 24, 2015.

2. Appellant seeks a 29 day extension.

3. The requested extension of time is needed because appellant’s attorney’s

schedule, family obligations, and time commitment to other cases has

prevented him from focusing on preparing appellant’s brief, appellant’s

attorney will soon be requesting supplementation of the Clerk’s Record, and

the additional time is needed to give appellant’s attorney adequate time to

prepare appellant’s brief.

4. Appellant Guam Industrial Services, Inc. has not previously sought any other

extensions nor has any extension been granted to appellant.

5. Counsel for Appellee Dresser-Rand Company does not oppose this motion.

Therefore, appellant Guam Industrial Services, Inc. requests an order allowing it to

file its appellant’s brief on or before December 23, 2015.

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Respectfully submitted,

THE DIETRICH LAW FIRM

/s/ Fred Dietrich

By:

Fred Dietrich State Bar 05857050 2211 Norfolk St., Suite 620 Houston, Texas 77098 Tel.: 713.830.7687 Fax: 713.893.6044 fdietrich@dietrich-law.com

ATTORNEY FOR APPELLANT GUAM INDUSTRIAL SERVICES, INC.

CERTIFICATE OF CONFERENCE

On November 12, 2015, I spoke with Mr. Kyle Reeb, attorney for appellee, about this motion and the extension requested, and Mr. Reeb informed me that appellee does not oppose this motion.

/s/ Fred Dietrich

Fred Dietrich

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Unopposed Motion for Extension of Time to File Appellant’s Brief was served on the following by e-service November 12, 2015:

Mr. Kyle C. Reeb PORTER HEDGES, LLP ATTORNEY FOR PLAINTIFF-APPELLEE DRESSER-RAND COMPANY

/s/ Fred Dietrich

Fred Dietrich