James P. Grantham v. J&B Sausage Company, Inc., D/B/A J Bar B Foods

Opinion

ACCEPTED 14-15-00227-cv

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/4/2015 3:41:24 PM CHRISTOPHER PRINE

CLERK

No. 14-15-00227-CV FILED IN 14th COURT OF APPEALS

HOUSTON, TEXAS

IN THE 14TH COURT OF APPEALS 6/4/2015 3:41:24 PM CHRISTOPHER A. PRINE

HOUSTON, TEXAS Clerk

James P. Grantham, Appellant V.

J & B Sausage Company, Inc. D/B/A J Bar B Foods and Eggleston & Briscoe, LLP, Appellees

APPELLANT’S MOTION FOR EXTENSION TO FILE REPLY BRIEF

TO THE HONORABLE FOURTEENTH COURTY OF APPEALS:

COMES NOW, James P. Grantham, Appellant, (Grantham) and files this Motion for Extension of Time to File its Reply Brief and in support thereof respectfully shows the following:

A. Introduction

1. This is an appeal from a final judgment rendered in the trial court.

This is Grantham’s first Motion for Extension of Time to file its Reply Brief.

2. Appellee filed his Brief on May 18, 2015. Grantham’s Reply Brief is presently due to be filed on or before June 7, 2015.

3. This seeks an extension of fifteen (15) days, up to and including June 22, 2015 for Grantham to file its Brief on the Merits.

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B. Bases for Extension

4. Grantham requests this extension not for purpose of delay, but so that justice may be done. Grantham has the following scheduled:

- An Administrative benefit review conference in Docket No.

15194278-01-BR before the Texas Department of Insurance, Division of Workers’ Compensation on June 8, 2015 in Houston, Texas.

- Unavoidable conflict.

PRAYER

Appellant respectfully requests the Court grant this Motion and for all other relief to which it may be entitled.

Respectfully,

/s/James P. Grantham James Pieper Grantham State Bar No. 00785922 Of Counsel, Trimble & Grantham 902 Heights Boulevard, Ste. 110 Houston, Texas 77008 jgrantham@texaslawspot.com (713) 863-8600 telephone (713) 863-1161 facsimile Appellant

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CERTIFICATE OF COMPLIANCE

I certify that I have a 366 word count checked by the word program in compliance with the Texas Rules of Appellate Procedure.

/s/James P. Grantham James Pieper Grantham

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CERTIFICATE OF SERVICE

I certify that a copy of the foregoing Appellant’s Motion for Extension of Time to file Reply Brief was served on counsel of record by the method indicated below on this 4th day of June 2015.

Via email David Smith, Esq., Eggleston & Briscoe, LLP 4800 Three Allen Center 333 Clay Street Houston, Texas 77002 Tel. (713) 659-5100 Fax. (713) 951-9920 Email: dws@egglestonbriscoe.com

/s/James P. Grantham James Pieper Grantham