Kori Lynn Plowman F/K/A Kori Lynn Ugalde v. Philip Andrew Ugalde

Opinion

ACCEPTED

01-14-00851-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

2/5/2015 1:57:02 PM

CHRISTOPHER PRINE

CLERK

No. 01-14-00851-CV

KORI LYNN PLOWMAN F/K/A IN THE FIRST FILED IN KORI LYNN UGALDE 1st COURT OF APPEALS HOUSTON, TEXAS

Appellant, 2/5/2015 1:57:02 PM

CHRISTOPHER A. PRINE

v. COURT OF APPEALS Clerk

Philip Andrew Ugalde Appellee. HOUSTON, TEXAS

APPELLANT'S SECOND MOTION TO EXTEND TIME TO FILE BRIEF Appellant asks the Court to extend the time to file brief.

A. Introduction

1. Appellant is Kori Lynn Plowman F/K/A Kori Lynn Ugalde. Appellee is Philip Andrew Ugalde.

2. No rule provides a deadline to file this motion to extend. See Tex. R. App.

P. 38.6(d).

B. Argument & Authorities 3. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d)

to extend the time to file the brief 4. Appellant requests an additional 30 days to file her brief, extending the time until March 9, 2015.

5. One extension has been granted to extend the time to file Appellants' brief 6. Appellant needs additional time to file her brief because appellant's counsel has been involved in multiple district court cases, federal court cases and mediations.

2

Appellants' counsel requires additional time to complete the drafting of the brief.

C. Conclusion

7. Appellant requires additional time to complete her brief.

D. Prayer

8. For these reasons, Appellant asks the Court to grant an extension of time to file her brief until March 9, 2015.

Respectfully submitted,

ALLAN A. CEASE & ASSOCIATES, P.C.

/s/ Allan A. Cease

BY: Allan A. Cease

Texas Bar No. 04040550

35 Sugar Creek Center Blvd, Suite 300 Sugar Land, Texas 77478

Tel. 281-980-0909

Fax 281-980-1069

Attorney for Appellant,

Kori Lynn Plowman F/K/A Kori Lynn Ugalde

3

VERIFICATION

STATE OF TEXAS

FORT BEND COUNTY

Before me, the undersigned notary, on this day personally appeared Allan A.

Cease, the affiant, a person whose identity is known to me. After I administered an oath to affiant, affiant testified:

"My name is Allan A. Cease. I am capable of making this verification. I have read the Appellant's Second Motion to Extend Time to File Brief The facts stated in it are within my personal knowledge and are true and correct."

°MU

Allan A. Cease

aW

SWORN TO AND SUBSCRIBED BEFORE ME by Allan A. Cease on February 5, 2015.

NICOLE COX

'Ifs Notary Public, State of Texas •• A „Lea-e

Th

NAry Public - State of Texas My Commission Expires

October 24, 2017

4

CERTIFICATE OF CONFERENCE I certify that I have conferred withSteven P. Lindamood and he is unopposed to this motion.

/s/ Allan A. Cease

Allan A. Cease

CERTIFICATE OF SERVICE

I certify that a copy of Appellant's Motion to Extend Time to File Brief was served on Appellee, Philip Andrew Ugalde, through counsel of record, Steven P. Lindamood of Connor & Lindamood, P.C., at 1221 Lamar Street, Ste. 1010, Houston, Texas 77010, by telephonic document transfer to fax number 713-654-8115, on February 5, 2015.

/s/ Allan A. Cease

Allan A. Cease