Leticia B. Loya v. Vitol, Inc., Michael Metz, and Antonio Maarraoui

Opinion

ACCEPTED 01-15-00197-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 8/17/2015 12:00:00 AM CHRISTOPHER PRINE CLERK

No.Ol-15-00197-CV FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE COURT OF ApPEALS 8/17/2015 8:48:00 AM FOR THE FmST DISTRICT OF TEXAS CHRISTOPHER A. PRINE AT HOUSTON Clerk

LETICIA LOYA, Appellant,

v. IAN TAYLOR, JACOBUS STERKEN, STICHTING TINSEL GROUP, VITOL HOLDING IIS.A., AND TINSEL GROUP, S.A., Appellees.

Appeal from the 190th Judicial District Court, Harris County, Texas Trial Court Cause No. 2012-33464

UNOPPOSED SECOND MOTION TO EXTEND TIME FOR FILING APPELLANT'S REPLY BRIEF

TO THE HONORABLE FIRST COURT OF APPEALS:

LETICIA LoyA, Appellant, moves this Court to grant an extension of

time to file Appellant's Reply Brief, and respectfully states:

1. Appellant's Briefis due to be filed with this court on or about August 14,

2015.

1 2. Appellant seeks a one (1) day extension of time to file Appellant's Brief,

which would make Appellant's Brief due on or before August 17, 2015.

3. This extension of time is necessary because lead counsel for Appellant's

legal assistant inadvertently overlooked the deadline while assisting another

counsel for trial in an unrelated matter. Also, lead counsel for Appellant

was/is participating in several oral arguments, appeals and/or trials with

deadlines prior to the August 14thdeadline:

• Universal Gold Coin v. FedEx et al, Western District of Tennessee (pre-trial motions) • Altamirano v. KONE, 136th Judicial District of Texas (pretrial motions) • Tomsic v. Real Flame Co., Inc., Eastern District of Texas (responses to motions to dismiss) • Bortz v. The Tuthill Corporation, d/b/a Blue Mountain Ski Area, Carbon County, Pennsylvania (pre-trial motions)

As a result, time constraints will make it difficult to adequately

prepare the brief in this appeal. This request is not filed for the purpose of

delay, but rather to afford counsel adequate time to prepare the reply brief.

Therefore, additional time is needed to adequately prepare the arguments in

this case.

4. Counsel for Appellant has conferred with counsel for Appellees Ian

Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A.,

Tinsel Group, S.A., and Miguel Loya, and Appellees do not oppose this

motion to extend time. 2 5. This is the second extension of time Appellant has sought for the filing of

the Appellant's Reply Brief.

For these reasons, LETICIALOYA, Appellant, requests that this Court

render an order extending the time for filing Appellant's Brief to and

including August 17,2015. Appellant also requests any other relief to which

she may be entitled.

Respectfully submitted,

PROVOST* UMPHREY LAW FIRM, L.L.P. 490 Park Street P. O. Box 4905 Beaumont, Texas 77704 (409) 835-6000 (409) 813-8682 (FAX)

By: / s / Jennifer Job Jennifer Job Texas State Bar No. 24050682 James Payne Texas State Bar No. 00788171 ATTORNEYS FOR APPELLANT

CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with counsel for Appellees Miguel Loya, Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and Tinsel Group, S.A. concerning this motion, and Appellees do not oppose the relief requested in this motion.

/ s / Jennifer Job

3 CERTIFICATE OF SERVICE

I hereby certify that a copy of this motion to amend notice of appeal has been sent to all known counsel of record via EFILE and/or certified mail, return receipt requested on August 15, 2015.

/ s / Jennifer Job Jennifer Job