Laurel Miller and Eliana Miller v. Debo Homes, LLC

Opinion

ACCEPTED 14-15-00004-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 10:30:52 AM CHRISTOPHER PRINE CLERK

CAUSE NO. 14-15-00004-CV

FILED IN 14th COURT OF APPEALS IN THE FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 7/7/2015 10:30:52 AM CHRISTOPHER A. PRINE Clerk LAUREL MILLER AND ELIANA MILLER Appellants

vs.

DEBO HOMES, LLC Appellee

From Cause No. 13-DCV-209822 In the 400th Judicial District Court Fort Bend County, Texas

APPELLEE’S FIRST UNOPPOSED MOTION TO ENLARGE THE TIME FOR FILING THEIR REPLY BRIEF

Craig Welscher State Bar No. 21167200 Nicholas Martinez State Bar No. 24087986 The Welscher Law Firm, P.C. 1111 North Loop West, Suite 702 Houston, Texas 77008 (713) 862-0800 – Telephone (713) 862-4003 – Facsimile Email: nmartinez@welscherlaw.com Attorneys for Appellee

1 TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW DEBO HOMES, LLC, the Appellee in the above-numbered

and styled appeal, by and through their counsel of record, Nicholas Martinez, and

respectfully moves for an enlargement of thirty (30) days for the filing of their

reply brief to Appellants’ opening brief, and in support thereof would respectfully

show unto the Court the following:

1. Appellants’ opening brief was filed on June 8, 2015.

2. Appellee’s reply brief is now due on July 8, 2015.

3. Appellee’s opening brief is due on July 27, 2015

4. Appellee has been diligently working on preparing their opening brief in

preparation for the July 27 deadline. Appellee has not had the opportunity to

prepare their reply brief.

5. Counsel for Appellants graciously does not oppose this enlargement of the

Appellee’s briefing deadline.

PRAYER

Wherefore, premises considered, the Appellee, Debo Homes, LLC, prays

that the Court enlarge the deadline for the filing of their opening brief thirty (30)

days, through and including August 7, 2015.

2 Respectfully submitted,

THE WELSCHER LAW FIRM

/s/ Nicholas Martinez Craig Welscher State Bar No. 21167200 Nicholas Martinez State Bar No. 24087986 The Welscher Law Firm, P.C. 1111 North Loop West, Suite 702 Houston, Texas 77008 (713) 862-0800 – Telephone (713) 862-4003 – Facsimile Email: nmartinez@welscherlaw.com Attorneys for Appellee

3 CERTIFICATE OF CONFERENCE

The undersigned has conferred with Mr. Timothy A. Hootman about this

Motion. On July 2, 2015, Mr. Hootman advised over via email that he is

unopposed to this Motion.

/s/ Nicholas Martinez Nicholas Martinez

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing

instrument was forwarded to all known counsel of record in the manner required

by Texas Rule of Appellate Procedure 9.5, on this the 7th day of July, 2015.

Via Electronic Service Timothy A. Hootman 2402 Pease St. Houston, Texas 77003 /s/ Nicholas Martinez Nicholas Martinez