Jarrod Dale Young v. Kathryn Renee Terral

Opinion

ACCEPTED 01-14-00591-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 12/31/2014 11:47:02 AM CHRISTOPHER PRINE CLERK In the COURT OF APPEALS FOR THE First District of Texas FILED IN 1st COURT OF APPEALS ____________ HOUSTON, TEXAS 12/31/2014 11:47:02 AM NO. 01-14-00591-CV CHRISTOPHER A. PRINE Clerk ____________

JARROD DALE YOUNG, Appellant

V.

KATHRYN RENEE TERRAL, Appellee ______________________________________

On Appeal from the 247th District Court Harris County, Texas Trial Court Cause No. 2012-37683 ________________________________________________

APPELLEE’S SECOND AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF

K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 1 OF 4 NO. 01-14-00591

JARROD DALE YOUNG, § IN THE DISTRICT COURT APPELLANT § § V. § 247TH JUDICIAL DISTR § KATHRYN RENEE TERRAL § APPELLEE § HARRIS COUNTY, TEXAS

APPELLEE’S SECOND AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF

Appellee, KATHRYN RENEE TERRAL, asks the Court to extend the time

to file its brief and respectfully shows the following:

A. INTRODUCTION

1. Appellant is JARROD DALE YOUNG; Appellee is KATHRYN RENEE

TERRAL.

2. Appellee’s brief is due on January 2, 2015.

3. Appellee respectfully requests an additional 30 days to file its brief, extending

the time until February 2, 2015.

4. The parties have agreed to this motion.

B. ARGUMENT & AUTHORITIES

5. Appellee's attorney Terisa Taylor of The Law Office of Terisa Taylor, P.C.,

needs additional time to file its brief because Appellee’s attorney has an unusually

heavy docket, staff attorney on vacation, and the research, preparation, and drafting

K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 2 OF 4 off the Appellee's brief will be disrupted by the heavy docket and absent of the staff

attorney.

6. One extension has been granted to extend the time to file Appellee's brief.

7. Appellee's Second Agreed Motion to Extend Time to File Appellee's Brief is

not sought for delay, but so that the interest of justice may be served.

C. PRAYER

4. For these reasons, KATHRYN RENEE TERRAL, asks this Court to grant an

extension of time to file response to appellant’s brief.

Respectfully submitted,

The Law Office of Terisa Taylor, P.C. 917 Franklin Street, Suite 510 Houston, Texas 77002 Tel: (713) 224-9900 Fax: (713) 224-9903 Email: service@ttaylorlawoffice.net

By: /s/ Terisa Taylor TERISA TAYLOR SBN: 24000240 GRACE M. CRUMP SBN: 24083482 Counsel for: Appellee

K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 3 OF 4 CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with Melissa E. Loveless’ staff via

telephone on December 31, 2014, and she has agreed and is unopposed to this Agreed

Motion to Extend Time to File Appellee’s Brief.

/s/ Terisa Taylor` TERISA TAYLOR GRACE M. CRUMP

CERTIFICATE OF SERVICE

I hereby certify that on the 31st day of December, 2014, a true and correct copy

of the foregoing instrument was served upon each attorney of record or party in

accordance with the Texas Rules of Civil Procedure.

K. TERRAL – APPELLEE’S AGREED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF PAGE 4 OF 4