Loren Rose Jeremy v. Nicholas Dusan Jeremy

Opinion

ACCEPTED

14-15-00279-cv

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS

11/16/2015 8:47:53 PM

CHRISTOPHER PRINE

CLERK

CASE NO. 14-15-00279-CV

LOREN ROSE JEREMY, § IN THE FOURTEENTH FILED IN

14th COURT OF APPEALS

§ HOUSTON, TEXAS Appellant, § 11/16/2015 8:47:53 PM § CHRISTOPHER A. PRINE v. § Clerk COURT OF APPEALS

§

NICHOLAS DUSAN JEREMY, et al., § §

Appellees. § HOUSTON, TEXAS

APPELLANT’S MOTION TO EXTEND TIME TO FILE THE BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Appellant asks the Court to extend the time to file his brief.

INTRODUCTION

1. Appellant is Loren Rose Jeremy; appellees are Nicholas Dusan Jeremy and Theresa Henry.

2. No rule limits the time within which to file this motion to extend time.

See TEX. R. APP. P. 38.6(d).

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. The Appellant’s brief was due on September 30, 2015.

5. Appellant requests an additional sixty days to file her brief, extending the time until November 30, 2015.

6. No extension has been granted to extend the time to file Appellant’s brief.

7. Appellant needs additional time to file her brief because she has been hospitalized with a severe gastrointestinal condition which has required multiple surgeries and for which she is finally recovering. Appellant has been unable to assist her counsel in this appeal for the past two (2) months, only recently being well enough to confer. Appellant has one additional medical procedure planned in the next two weeks, but after that should be able to fully assist her counsel in prosecuting her appeal.

CONCLUSION

8. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time to file the brief. Appellant requests an additional sixty days to file her brief, extending the time until , because Appellant has been extremely ill these past few months and only now is able to assist counsel in the prosecution of this appeal.

PRAYER

9. For these reasons, Appellant asks the Court to grant an extension of time to file her brief until November 30, 2015.

3

Respectfully submitted,

By: __/s/ Mark Aronowitz____________ MARK ARONOWITZ

State Bar No.: 00793281

Attorney for Loren Rose Jeremy P.O. Box 1201

Texas City, TX 77592-1201 Tel: (281) 402-6780

Fax: (281) 715-4284

CERTIFICATE OF COMPLIANCE I certify that I have complied with Rule 12 of the Texas Rules of Appellate Procedure because this motion is only 423 words.

_____/s/ Mark Aronowitz____________ MARK ARONOWITZ

CERTIFICATE OF SERVICE

I certify that a copy of the Appellant’s Motion to Extend Time to File the Brief was served on all parties through their counsel of record by a method permitted by Texas Rule of Appellate Procedure 9.5 on November 17, 2015.

_____/s/ Mark Aronowitz____________ MARK ARONOWITZ