Levent Ulusal v. Lentz Engineering, L C

Opinion

ACCEPTED 01-15-00597-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 11:25:43 PM CHRISTOPHER PRINE CLERK

01-15-00597-CV

IN THE COURT OF APPEALS FILED IN 1st COURT OF APPEALS FOR THE FIRST COURT OF APPEALS DISTRICTHOUSTON, TEXAS HOUSTON, TEXAS 12/2/2015 11:25:43 PM CHRISTOPHER A. PRINE Clerk

LEVENT ULUSAL, Appellant, V. LENTZ ENGINEERING, L C Appellee.

MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

Daniel Kistler Daniel Kistler, Attorney at Law Office Address: 17041 El Camino Real Ste. 204 Houston, Texas 77058 Mailing Address: 2617C West Holcombe No. 421 Houston, Texas 77025 Telephone: (713) 855-0827 Facsimile: (866) 352-5124 kistlerattorney@comcast.net

ATTORNEY FOR APPELLANT MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

Comes now, Ulusal Levent, Appellant herein, and files this his first

Motion for Extension of Time to File Reply Brief, and in support would

show the following:

1. Appellee Lentz Construction, L.C. filed its Brief on November

12, 2015. Pursuant to Rule 38.6(c), Tex. R. App. P., the deadline for filing

Appellant’s Reply Brief is December 2, 2015.

2. Appellant seeks an additional fourteen (14) days, or until

December 16, 2015, in which to file its Reply Brief.

3. Appellant’s counsel has been delayed in the preparation and

finalization of this brief due to trial commitments in Cause No. 2014-43377;

Christopher Stanzel, et al, v. John Hinkle, pending in the 190th Judicial

District Court of Harris County, Texas, which is presently set for trial on

December 7, 2015; Cause No. 2014-15521; Harris County, et al v. L V

Thompson, 55th Judicial District Court of Harris County, Texas, which is

presently set for trial on December 9, 2015, and Cause No. 2014-39578;

Harris County, et al v. Ramona Jones, et al; which was set for trial on

December 1, 2015, and not continued from that setting until the trial date.

4. Appellant’s counsel believed that he would be able to complete

this Reply Brief, despite the time required for trial preparations in the cases

1 cited above, other matters which required his attention during the last 20

days, and the Thanksgiving Holiday. However, it has become apparent that

Appellant will require additional time in which to complete his Brief.

Appellant reasonably requires an additional fourteen (14) days in which to

complete and file his Brief.

5. This is the first motion for an extension of time to file

Appellant’s Reply Brief.

CERTIFICATE OF CONFERENCE

6. Due to the late hour in filing this Motion, Appellant’ counsel is

not able to contact counsel for the Appellee, Lentz Engineering, L.C.

Appellant’s counsel shall apprise the court as soon as possible on whether

Appellee has any objection to the relief requested.

Wherefore, premises considered, Appellant Levant Ulusal hereby

requests that the court grant a fourteen (14) day extension of time for

Appellant to file his Reply Brief, and for all other and further relief, at law

and in equity, to which Appellant may be justly entitled.

Respectfully submitted,

/s/Daniel Kistler Daniel Kistler, Attorney at Law Office Address: 17041 El Camino Real Ste. 204

2 Houston, Texas 77058 Mailing Address: 2617C West Holcombe No. 421 Houston, Texas 77025 Telephone: (713) 855-0827 Facsimile: (866) 352-5124 kistlerattorney@comcast.net

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

On this 2nd day of December, 2015, a true and correct copy of

the foregoing Motion for Extension of Time to File Reply Brief of

Appellant Levant Ulusal was served on all counsel of record and

pro se parties by certified mail, return receipt requested, facsimile

transmission, electronic transmission and/or hand delivery.

Timothy R. Ploch via facsimile: (713) 862-7575 and Linda M. Talbot email: lawplochstaff@flash.net Timothy R. Ploch, P.C. 730 N. Post Oak Rd., Ste 100 Houston, Texas 77024

Keith Livesay Livesay Law Office Brazos Suites No. 9 McAllen, TX. 78504 Via email to: RGVAppellateLaw@yandex.com

/s/ Daniel Kistler