Kimberly R. Redo v. Katherine Moore

• Court: Court of Appeals of Texas
• Decided: June 1, 2015
• Docket: 14-14-00922-CV
• Status: Published

Opinion

ACCEPTED 14-14-00922-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/1/2015 12:03:00 PM CHRISTOPHER PRINE CLERK

No. 14-14-00922-CV ____________________________ FILED IN IN THE COURT OF APPEALS FOR THE 14th COURT OF APPEALS HOUSTON, TEXAS FOURTEENTH DISTRICT OF TEXAS 6/1/2015 12:03:00 PM CHRISTOPHER A. PRINE Clerk Kimberly R. Redo Appellant,

v.

Katherine Moore Appellee.

On Appeal from County Court at Law No. One (1) Of Harris County, Texas Trial Court Cause No. 1029105

UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT

TO THE HONORABLE JUSTICES OF THIS COURT:

Kimberly R. Redo, Appellant, file this Unopposed Motion for Extension of Time to File

Brief of Appellant and would show the Court as follows:

1. Appellant’s brief is due on Monday, June 1, 2015.

2. Appellant respectfully requests an extension of time for 30 days to file her brief.

3. In addition to his regular office and client commitments and responsibilities,

counsel for Appellant has been required to prepare for and attend to various other matters

including:

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 1 (a) Attend trial in Cause No. 2013-22591, styled Capital Plastic & Bags, Inc. v. Frank Zhang and Daxwell Group, LLC, f/k/a Daxwell Group, L.P., pending in the 295th Judicial District Court of Harris County, Texas.

(b) Prepare for and attend depositions in Cause No. 2012-11729, styled PMB Precision Medical Billing v. Bay Area Podiatry Associates, pending in the 165th Judicial District Court of Harris County, Texas.

(c) Prepare for and attend non-party deposition in Cause No. 2014-50460, styled 6100 Clarkson L.P., et. al. v. Melvin Grant, et al., pending in the 295th District Court of Harris County, Texas.

(d) Prepare for and attend pre-trial conference in Case No. 4:15-cv-859, styled Carmelita Sagum v. Deutsche Bank National Trust Company, pending in the United States District Court for the Southern District of Texas, Houston Division.

(e) Prepare for and attend oral argument in Cause No. 2009-65488 in Case No. 14-14- 00744-CV, styled Mega Builders, Inc., d/b/a Mega & Associates v. Paramount Stores, Inc., and Community National Bank; In Fourteenth Court of Appeals.

(f) Prepare for and travel overseas to the Netherlands and Belgium, having left on Friday, May 15, 2015, and returning on Sunday, May 24, 2015.

In addition to the above, the undersigned counsel has the following upcoming deadlines:

(g) Prepare a response to Motion for Summary Judgment and attend Summary Judgment hearing on June 5, 2015, in Cause No. 2014-16000; styled Heritage Park Terrace Homeowners Association vs. Mohammad F. Akbar, pending in the 113th Judicial District of Harris County, Texas.

(h) Prepare for and attend TCEQ hearing in SOAH Docket No. XXX-XX-XXXX; TCEQ Docket No. 2014-0908-PST-E, styled In the Matter of an Enforcement Action Against Adnan Najm d/b/a Kathy’s Sunmart, RN101943140, on June 11, 2015.

(i) Prepare for and attend hearing on Harris County’s Motion for Summary Judgment on June 12, 2015, in Cause No. 2011-52524, styled Harris County, Texas, Plaintiff, vs. S.K. and Brothers, Inc., and Trey Melcher and Yvonne Evie Melcher, Trustees of the Evie Melcher Non-Exempt Trust, Defendants, pending in the 215th Judicial District Court, of Harris County, Texas.

(j) Prepare Joint Pre-Trial Statement in Adversary Case No. 14-03320, styled Gulam Gulamali v. Ngo Xuan Dinh and Nina Nhathuy Dinh, pending in the Southern District of Texas, which is due June 19, 2015.

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 2 (k) Attend hearing on June 19, 2015, in Cause No. 14-DCV-214552, styled In the Matter of the Marriage of Edward Ochuwa and Nwabugwu Ochuwa, pending in the 328th Family District Court of Fort Bend County, Texas.

4. One previous extension for time was granted to Appellant on April 13, 2015, with

regard to the filing of her brief.

5. This Motion is not sought for delay only, but in order that justice may be properly

served.

PRAYER

Appellant Kimberly R. Redo, respectfully requests that this Court grant her request for an

extension of 30 days, until Wednesday, July 1, 2015, to file her brief. Appellant prays for any

other relief to which it is entitled.

Respectfully submitted,

WILLIAM F. HARMEYER & ASSOCIATES

/s/William F. Harmeyer William F. Harmeyer State Bar No. 09019000 475 Arena Tower One 7322 Southwest Freeway Houston, Texas 77074 Tel: (713) 270-5552 Fax: (713) 270-7128 Email: wharmeyer@harmeyerlaw.com Attorney for the Appellant, Kimberly R. Redo.

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 3 CERTIFICATE OF CONFERENCE

I hereby certify that I have contacted Mr. Steven Messer, attorney for Appellee, Katherine Moore, as to the merits of the forgoing motion, and that he is unopposed to this Motion for Extension of Time to File Appellant’s Brief.

/s/William F. Harmeyer William F. Harmeyer

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was served on the following parties or counsel of record on this 1st day of June, 2015, in accordance with Rule 9.5 of the Texas Rules of Appellate Procedure.

Mr. Steven Messer Haynes and Boone, LLP 1221 McKinney, Suite 2100 Houston, Texas 77010-2007 Attorney for Appellee, Katherine Moore Via Fax: (713) 236-5507

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Page | 4