in Re Irving Drobny, as Representative of National Accident Insurance Group and National Accident Insurance Underwriters

Opinion

ACCEPTED 01-15-00435-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 7/30/2015 4:19:01 PM CHRISTOPHER PRINE CLERK

01-15-155-CV FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE FIRST COURT OF APPEALS FOR TEXAS7/30/2015 4:19:01 PM CHRISTOPHER A. PRINE Clerk

IRVING DROBNY, AS REPRESENTATIVE OF NAIU AND NAIC, Appellants,

v.

ANICO, Appellee.

ON APPEAL FROM 405TH DISTRICT COURT GALVESTON COUNTY, TEXAS CAUSE NO. 12-CV-1131

UN-OPPOSED MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE JUSTICES OF THE FIRST COURT OF APPEALS:

Appellants ask this court to grant this motion for extension of time to file the

Appellant’s Brief for three weeks.

1. The Appellant’s Brief was due July 30, 2015

2. Appellant’s counsel has been responding to a Petition for Rehearing Enc Banc, in

cause number 14-40114, McCaig v. Wells Fargo, in the Fifth Circuit, including

response, and sur-reply.

3. In part because of the press of that business, as well as a jury trial that was held

July 6 – 8, Counsel did not realize that she had not obtained a copy of the record

from the Clerk. It is normal in this practice to work from original (highlighted and

marked up) copies of documents, and add pagination to the record as one of the

last steps. The record was checked out today, July 30, 2015.

4. In conferencing with opposing counsel, she is going on vacation and would prefer

that the brief not be filed during her absence, so she will have a full period to

respond. She graciously does not oppose this request.

PRAYER

For all these reasons, appellant asks this Court to grant an extension of time to file

the Appellant’s Brief to August 20, 2015.

Respectfully submitted,

_/s/ Savannah Robinson ________________ Savannah Robinson Texas Bar No. 17108150 1822 Main Danbury, TX 7534 Telephone: 979-922-8825 Savannahrobinson@aol.com Attorneys for Appellant

CERTIFICATE OF CONFERENCE

I emailed and forwarded correspondence by fax to Roni Mihaly, the attorney for appellee, who does not oppose this extension.

3

_/s/ Savannah Robinson ________________ Savannah Robinson

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Opposed Motion to Extend Time to File Appellant’s Brief was served on all counsel of record by first class mail on July 30, 2015.

_/s/ Savannah Robinson_________________ Savannah Robinson