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

11/18/2015 11:21:28 AM 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

11/18/2015 11:21:28 AM 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’ MOTION FOR EXTENSION OF TIME TO FILE BRIEF

LAW OFFICE OF GREGORY N. JONES

By: /s/ Gregory N. Jones SBN 10889450 2323 S. Shepherd, 14th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax

Counsel for Appellees

As pointed out in Appellee’s last request for extension, Appellees’ counsel

has health issues having incurred several seizures. As a result of various

prescribed medications, counsel has been unable to completely

function, including driving until mid-December 2015. When

coupled with the Thanksgiving and Christmas holiday seasons ,

Appellees therefore respectfully request an extension of sixty (60) days 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 was due September 17, 2105. This

date was extended to November 19, 2015, as a result of Appellees’ previous

unopposed request for extension.

2. Appellees’ counsel’s health condition has prevented Appellees’

counsel from devoting the necessary time and attention to their response brief.

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PRAYER / RELIEF REQUESTED

For the foregoing reasons, Appellees request an extension of at least 30-

day the deadline to file their brief, or until January19, 2016.

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 appellees’ counsel who

indicated that appellees are opposed 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 441 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 November 18th, 2015:

/s/ Gregory N. Jones Gregory N. Jones

Daniel W. Jackson, SBN 00796817 William L. Maynard Scott K. Vastine, SBN 24056469 1300 Post Oak Blvd. Ste. 2500 3900 Essex Lane, Suite 1116 Houston, Texas 77056 Houston, Texas 77027 Fax: (713) 960-1527 (713) 527-8850 – fax daniel@jacksonlaw-tx.com scott@jacksonlaw-tx.com