Inwood Forest Community Improvement Association v. Toan Van Nguyen

Opinion

ACCEPTED 14-14-00825-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 1:19:45 PM CHRISTOPHER PRINE CLERK

NO. 14-14-00825-CV

FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS, 7/7/2015 1:19:45 PM HOUSTON, TEXAS CHRISTOPHER A. PRINE Clerk

INWOOD FOREST COMMUNITY IMPROVEMENT ASSOCIATION, Appellant

v.

ELIO ARCE, ET AL. Appellees

On interlocutory appeal from the 165th Judicial District Court of Harris County, Texas ______________________________________________________________

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

HOOVER SLOVACEK LLP Dylan B. Russell State Bar No. 24041839 russell@hooverslovacek.com Galleria Tower II 5051 Westheimer, Suite 1200 Houston, Texas 77056 Telephone: (713) 977-8686 Facsimile: (713) 977-5395 ATTORNEYS FOR APPELLANT

171327-00331 DBR 7/7/2015 00979216.WPD 1 INWOOD FOREST COMMUNITY IMPROVEMENT ASSOCIATION,

Appellant, in the above-styled and numbered cause, file this Appellant’s Motion for

Extension of Time to File Reply Brief on the Merits and requests that the Court enter

an order extending the time for the filing of its Reply Brief with the Court through,

and including, July 17, 2015, and in support thereof would respectfully show the

following:

1. This is Appellant’s first request for an extension of time—for one

additional week—to file its Reply Brief. This motion is not sought for delay only but

so that justice may be done.

2. Furthermore, Mr. Russell, counsel for Appellant and chief brief-writer,

needs additional time to prepare the Reply Brief in light of being chief brief-writer in

Cause No. 15-20213; Evanston Insurance Company vs. Lapolla Industries, Inc.; in the

U.S. Court of Appeals for the 5th Circuit, which said brief is also currently due on July

13, 2015.

CERTIFICATE OF CONFERENCE

Counsel for Appellant has contacted counsel for Appellees regarding this

motion, and Appellees’ counsel, has indicated that they are not opposed to this Motion

for Extension.

WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully prays

that the Court grant its Motion for Extension of Time to File Reply Brief and extend

171327-00331 DBR 7/7/2015 00979216.WPD 1 -2- the time for it to file Appellant’s Reply Brief on the Merits through, and including,

July 17, 2015.

Respectfully submitted,

HOOVER SLOVACEK LLP

By: /s/ Dylan B. Russell DYLAN B. RUSSELL State Bar No. 24041839 Galleria Tower II 5051 Westheimer, Suite 1200 Houston, Texas 77056 Telephone: 713-977-8686 Facsimile: 713-977-5395 russell@hooverslovacek.com

ATTORNEYS FOR APPELLANT, INWOOD FOREST COMMUNITY IMPROVEMENT ASSOCIATION

CERTIFICATE OF SERVICE

I hereby certify that on this, the 7th day of July, 2015, a true and correct copy of the foregoing document was served in accordance with the Rules to all counsel of record and/or pro se parties, if any.

/s/ Dylan B. Russell Dylan B. Russell

171327-00331 DBR 7/7/2015 00979216.WPD 1 -3-