Harris County, Texas v. Stephanie Jo Baker

Opinion

ACCEPTED 01-15-00930-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/29/2015 1:55:20 PM CHRISTOPHER PRINE CLERK

NO. 01-15-00930-CV IN THE COURT OF APPEALS FIRST DISTRICT OF TEXAS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 12/29/2015 1:55:20 PM CHRISTOPHER A. PRINE Clerk Harris County, Texas, Appellant,

v.

Stephanie Jo Baker, Appellee ________________________________________________________________

ON APPEAL FROM THE 295TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2014-02549

APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME

_________________________________________________________________

Tritico Rainey, P.L.L.C. L. JAMES KRELL State Bar No. 24072191 RON S. RAINEY State Bar No. 16484425 1523 Yale Street Houston, Texas 77008 (713) 581-3399 (713) 581-3360 (Facsimile)

ATTORNEYS FOR APPELLEE

1 TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW, STEPHANIE JO BAKER, Appellee herein, by and through

their undersigned counsel, and files this Appellees’ Unopposed Motion for

Extension of Time to File her Appellee’ Brief in compliance with Rules 38.6(d)

and 10.5 of the Texas Rules of Appellate Procedure. In support of this motion,

Appellant would show as follows:

(a) After receiving an extension, Appellants’ brief was filed on December 16, 2015.

(b) Appellee requests an extension of fourteen (14) days, until January 18, 2016 to prepare her brief.

(d) This is Appellee’s first request and/or motion for an extension of time.

(e) Appellee is requesting this extension so that she might adequately brief the issues in dispute in this case, and it is not sought for the purpose of an improper delay.

(f) the undersigned has conferred with counsel for the Appellant, and the Appellant is unopposed to this motion.

Appellants allege good cause exists for this request due to the undersigned’s

litigation and appellate schedule. The undersigned is currently assisting in both

criminal and civil matters at the trial and appellate level for his firm, Tritico

Rainey, PLLC. Moreover, while assisting in the drafting and preparation of these

appeals, the undersigned is also maintaining a litigation practice throughout the

state of Texas

2 WHEREFORE, PREMISES CONSIDERED, Appellants respectfully

request that this Honorable court grant an extension of fourteen (14) days, up to

and including, Monday, January 18, 2016, to file Appellee’s brief.

Respectfully submitted,

TRITICO RAINEY, PLLC

By: /s/ L. James Krell L. JAMES KRELL State Bar No. 24072191 RON S. RAINEY State Bar No. 16484425 1523 Yale Street Houston, Texas 77008 (713) 581-3399 (713) 581-3360 (Facsimile) ATTORNEYS FOR APPELLEE

3 CERTIFICATE OF CONFERENCE

I hereby certify that on December 29, 2015, I conferred with Keith Toler, counsel for Appellant, by email regarding this motion. He indicated to me that he was unopposed to this motion,

/s/ L. James Krell L. James Krell

CERTIFICATE OF SERVICE

Pursuant to Rule 9.5(b)(1) of the Texas rules of Appellate Procedure, I do hereby certify that if the email address for counsel of record for the Appellee is on file with the electronic filing manager, then a true and correct copy of the foregoing pleading was served electronically through the electronic filing manager. In addition, I do hereby certify that a true and correct copy of the foregoing pleading was served by facsimile to Mr. Keith Toler, on the 29th day of December, 2015.