Harpinder Singh, Jagjit S. Gill, and Baldev Singh v. Gurnam Singh Sandhar, Inqlabi Thandi, Daljit Singh, Baljinder Singh Bhatti, Sodagar Singh Virk, and Baljinder Singh

• Court: Court of Appeals of Texas
• Decided: July 2, 2015
• Docket: 14-15-00087-CV
• Status: Published

Opinion

ACCEPTED 14-15-00087-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/2/2015 10:58:58 AM CHRISTOPHER PRINE CLERK

No. 14-115-00087-CV

FILED IN 14th COURT OF APPEALS In the Court of Appeals for the HOUSTON, TEXAS Fourteenth District of Texas at Houston 7/2/2015 10:58:58 AM CHRISTOPHER A. PRINE Clerk

HARPINDER SINGH, ET AL.

Appellant

V.

GURNAM SINGH SANDHAR ET AL.

Appellee

On Appeal from the 55th Judicial District Court Harris County, Texas Trial Court Case No. 2013-51397

APPELLANT’S MOTION FOR AN EXTENSION OF TIME TO FILE APPELLANT’S BRIEF ON THE MERITS

To the Honorable Fourteenth Court of Appeals:

1. Appellants’, Harpinder Singh, et al., respectfully file this

motion for a thirty (45) day extension of time to file the Clerk’s record and

in support respectfully state as follows:

1 2. The brief of Appellants is due on July 6, 2015. This is

Appellants’ first request for an extension of time to file their brief.

3. Appellants are requesting 45 days from the granting of this

Motion in which to file their Appellant’s Brief on the Merits.

4. The counsel for Appellant is unable to confer with all

Appellees, as they are individuals unrepresented by counsel, and the

undersigned does not have a telephone number for each Appellee.

5. Counsel for the Appellant seeks this extension of time because

the Reporter’s record was just filed on June 3, 2015. Since that time,

Appellant’s counsel, Kristen Coleman, has had multiple evidentiary hearings

which have required significant time to prepare. Ms. Coleman also went on a

three day vacation. Ms. Coleman seeks additional time to prepare the

Appellant’s brief.

6. It is for these reasons that counsel for Appellant has been

unable to complete the Brief on the Merits and is requesting an extension of

time. The undersigned attorney understands the importance of deadlines and

is not requesting this extension for reasons of delay only, but that justice

may be done.

2 WHEREFORE, PREMISES CONSIDERED, the Appellant

respectfully requests the Court to extend the time for filing her Brief on the

Merits in this cause by 30 days from the date of the Court’s granting of this

Motion.

Respectfully submitted,

WOODFILL LAW FIRM, PC

/s/ Kristen Coleman____________ Kristen Coleman State Bar No.: 24038825 kcoleman@woodfilllaw.com River Oaks Green 3131 Eastside St., Suite 450 Houston, Texas 77098 Telephone: 713-751-3080 Facsimile: 713-751-3058

Certificate of Conference

Pursuant to Tex. R. App. P. 10.1(5), this is to certify that I did not confer with the individual Appellees, because they are not represented by counsel.

/s/ Kristen S. Coleman Kristen Coleman Attorney for Appellant

3 CERTIFICATE OF SERVICE

I hereby certify that on this 2nd day of July, 2015, a true and correct copy of the foregoing document has been served on counsel below:

Via USPS First Class Mail Gurnam Singh Sandhar 7 Harbor Bend Drive Houston, Texas 77070

Via USPS First Class Mail Inqlabi Thandi 9910 Oxted Spring, Texas 77379

Via USPS First Class Mail Daljit Singh Baganti 19027 Rustling Ridge Lane Tomball, Texas 77377

Via USPS First Class Mail Baljinder Singh Bhatti 14355 Cornerstone Village Dr. #911 Houston, Texas 77014

Via USPS First Class Mail Sodagar Singh Virk 2413 Air Line Dr. Brenham, Texas 77833

Via USPS First Class Mail Baljinder Singh 12206 Winderwick Houston, Texas 77066

Via Email Briseida Luna /s/ Kristen S. Coleman Kristen Coleman