Le Nguyen v. Elena Lopez, Individually and as of Representative of and on Behalf of the Estate of Jeanette Lopez and Caristina and Miguel Lerma, Individually and on Behalf of Bernice Lerma, a Minor, and on Behalf of All Known Heirs

Opinion

ACCEPTED 07-15-00128-CV SEVENTH COURT OF APPEALS AMARILLO, TEXAS 8/31/2015 6:23:29 PM Vivian Long, Clerk

No. 07-15-00128-CV ___________________________________________________ FILED IN LE NGUYEN, 7th COURT OF APPEALS Appellant AMARILLO, TEXAS 8/31/2015 6:23:29 PM v. VIVIAN LONG CLERK ELENA LOPEZ, Individually and as of Representative of and on behalf of THE ESTATE OF JEANETTE LOPEZ and CARISTINA AND MIGUEL LERMA, Individually and on behalf of BERNICE LERMA, a minor, and on behalf of all known heirs;

Appellees

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APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF ___________________________________________________

TO THE HONORABLE COURT OF APPEALS:

LE NGUYEN, Appellant, moves this Court to grant an extension of time to file her Reply

Brief to the Appellee’s Brief, and respectfully states:

1. Le Nguyen’s Reply Brief is due to be filed with this Court on August 31, 2015,

which is prior to submission on September 1, 2015.

2. Le Nguyen seeks an extension of time until Tuesday, September 8, 2015, to file

her Reply Brief, and a similar extension for submission of the case until Wednesday,

September 9, 2015.

3. This extension of time is necessary because counsel for Nguyen has scheduling

conflicts in other proceedings which have delayed preparation of the reply brief. No previous

extension has been requested by Appellant Nguyen for filing the reply brief.

4. Counsel for Appellee does not oppose this request for extension.

Appellant’s Unopposed Motion to Extend Time to File Reply Brief Page 1 For these reasons, Appellant, LE NGUYEN, requests that this Court grant an extension of

time for Appellant to File her Reply Brief until September 8, 2015, and to extend the date for

submission of the case until September 9, 2015, together with any other relief to which she may

be entitled.

Dated: August 31, 2015. Respectfully submitted,

/s/ Joyce W. Lindauer Joyce W. Lindauer State Bar No. 21555700 Joyce Lindauer, PLLC 12720 Hillcrest Suite 625 Dallas, TX 75230 Telephone (972) 503-4033 Fax (972) 503-4034 Joyce@joycelindauer.com

CERTIFICATE OF SERVICE

I, Joyce W. Lindauer, certify that a true copy of the foregoing pleading was served upon the following, on the 31st day of August, 2015:

Charles Chad Baruch Mohammad Said The Law Office of Chad Baruch Modjarrad Abusaad & Said Law Firm 3201 Main Street 212 West Spring Valley Road Rowlett, Texas 75088 Richardson, TX 75081

R. Douglass Scott Annette Loyd Vanicek Law Office of Craig Zimmerman 4528 W. Vickery Blvd., Suite 202 3901 Arlington Heights Blvd., Suite 200 Fort Worth, TX 76107 Arlington, Texas 76018

/s/ Joyce W. Lindauer Joyce W. Lindauer

Appellant’s Unopposed Motion to Extend Time to File Reply Brief Page 2