Joan DeYoung, Stephen DeYoung, M.D., and David DeYoung v. William L. Maynard, Individually and as of the Estate of Judy Page Maynard, and Maynard Properties, L.P.

Opinion

ACCEPTED

01-15-00260-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS 9/17/2015 1:34:57 PM CHRISTOPHER PRINE

NO. 01-15-00260-CV CLERK

IN THE COURT OF APPEALS

FOR THE 1ST JUDICIAL DISTRICT OF TEXAS AT HOUSTON FILED IN 1st COURT OF APPEALS

HOUSTON, TEXAS 9/17/2015 1:34:57 PM CHRISTOPHER A. PRINE

JOAN DEYOUNG, STEPHEN DEYOUNG, M.D, AND DAVID DEYOUNG, Clerk

Appellants,

V.

Judy Page Maynard, William L. Maynard, Maynard Properties, L.P., Appellees.

FROM THE 270TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF

Gregory N. Jones SBN 10889450 Law Office of Gregory N. Jones 2323 S. Shepherd, 14th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax Counsel for Appellees

Appellees’ Unopposed Motion for Extension of Time

Appellees’ counsel has been involved in several litigation

matters out of the county and State litigation matters, Appellees

respectfully requests a thirty (30) day extension of the deadline to file their

response brief in this appeal.

BACKGROUND FACTS

1. On March 19, 2015, the DeYoungs filed their notice of appeal.

The clerkʼs record was filed on June 16, 2015, the Appellants’ brief was filed

on August 17, 2015, which means that Appellees’ brief is due September

17, 2105.

2. Appellees’ counsel is handling several complex cases that

have required an inordinate amount of time and attention over the past

several months.

3. These matters, and the resulting time constraints, have

prevented Appellees’ counsel from devoting the necessary time and

attention to their response brief.

4. This is the Appellees’ counsel first request for an extension

of time to file their response brief, which is unopposed.

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PRAYER / RELIEF REQUESTED

For the foregoing reasons, appellants Joan DeYoung, Stephen

DeYoung, M.D., and David DeYoung request a 30-day extension of the

deadline to file his brief, which would make the DeYoungsʼ brief due on

August 17, 2015 (August 15th is a Saturday).

Respectfully submitted, Law Office OF GREGORY N. JONES

/s/ Gregory N. Jones Gregory N. Jones 2323 S. Shepherd, 14th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax gjones@gnjlaw.net Counsel for Appellees

CERTIFICATE OF CONFERENCE

I certify to the Court that I have conferred with appelleesʼ counsel who

indicated that appellees are unopposed to the relief sought by this motion.

/s/ Gregory N. Jones Gregory N. Jones

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CERTIFICATE OF COMPLIANCE

Pursuant to TEX. R. APP. P. 9.4(i), I certify to the Court that the

foregoing document contains 371 words. In calculating the word count, I

relied on the “Word Count” function of the computer program used to

generate this document.

/s/ Gregory N. Jones Gregory N. Jones

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing document has been electronically

served on all counsel of record on September 17, 2015:

Daniel W. Jackson, SBN 007968 William L. Maynard Scott K. Vastine, SBN 24056469 1300 Post Oak Blvd., Suite 2500 3900 Essex Lane, Suite 1116 Houston, Texas 77056 Houston, Texas 77027 (713) 623-0887 (713) 522-4435 (713) 960-1527 – fax (713) 527- 8850 – fax daniel@jacksonlaw-tx.com scott@jacksonlaw-tx.com

/s/ Gregory N. Jones Gregory N. Jones