Joslyn M. Johnson, Individually and as for the Estate of Rodney Johnson v. City of Houston

Opinion

ACCEPTED 14-15-00176-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 1:14:27 PM CHRISTOPHER PRINE CLERK

No. 14-15-00176-CV FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 1:14:27 PM IN THE FOURTEENTH COURT OF CHRISTOPHER APPEALS A. PRINE Clerk AT HOUSTON, TEXAS

JOSLYN M. JOHNSON, INDIVIDUALLY AND AS EXECUTRIX FOR THE ESTATE OF RODNEY JOHNSON, DECEASED Appellant

v.

CITY OF HOUSTON Appellee

On Appeal from the 125TH Judicial District Court of Harris County, Texas (Cause No. 2008-53919)

APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Appellant asks the Court to extend the time to file her Brief.

1. This Motion is filed by Appellant pursuant to TEX. R. APP. P. 10.5

(b) and 38.6(d).

2. The matter is on appeal from the 125TH Judicial District Court in Harris

County, Texas; Cause No. 2008-53919 styled as Joslyn Johnson, Individually

and as Executrix for the Estate of Rodney Johnson v. City of Houston. The final order made the basis of this appeal was signed by the trial court on

November 17TH 2014.

3. Appellant requests an extension of at least ONE HUNDRED TWENTY

DAYS (120) days from the original due date of May 1ST 2015 to file her brief.

4. This is the second extension sought by the Appellant.

5. The Appellee requested the trial court clerk to supplement the record

with additional documents. Those records were only made available recently,

and after the expiration of Appellant’s first extension.

For these reasons the Appellant respectfully requests the Court to grant

an extension to file her brief.

Respectfully submitted,

LAW OFFICES OF BEN DOMINGUEZ, II

BY:______________________ Ben Dominguez, II SBN: 00786415 The Esperson Buildings 808 Travis, Suite 907 Houston, Texas 77002 Tel: (713) 224-7333 Fax: (832) 201-7071 Bdominguez@bendominguez.com David M. Medina SBN: 88 5800 Memorial Drive, Suite 890 Houston, Texas 77007 ATTORNEYS FOR APPELLANT JOSLYN JOHNSON CERTIFICATE OF CONFERENCE

I hereby certify that I telephoned Mr. John Wallace on 7th of July 2015 to discuss this motion and I left a detailed message for the purpose of my call. I have not received a return call regarding his position on this motion.

_______________________________ BEN DOMINGUEZ, II

CERTIFICATE OF SERVICE

I hereby certify that the foregoing instrument was served upon all counsel of record via fax or ECF on July 7, 2015.

John B. Wallace Sr. Assistant City Attorney john.wallace@houstontx.gov

______________________________ BEN DOMINGUEZ, II