Martin L. Graman v. Jason L. Graman

Opinion

ACCEPTED 05-14-01254-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 10/20/2015 12:00:34 PM LISA MATZ CLERK

NO. 05-14-01254-CV FILED IN 5th COURT OF APPEALS IN THE COURT OF APPEALS DALLAS, TEXAS FOR THE FIFTH DISTRICT OF TEXAS 10/20/2015 12:00:34 PM AT DALLAS LISA MATZ Clerk

MARTIN L. GRAMAN, Appellant

v.

JASON L. GRAMAN, Appellee

On Appeal from the 4 l 6th Judicial District Court of Collin County, Texas Cause No. 416-51105-2012

UNOPPOSED MOTION TO POSTPONE ORAL .ARGUMENT OF APPELLANT

Jeffrey Goldfarb Texas Bar No. 00793820 GOLDFARB PLLC Saint Ann Court 2501 N. Harwood, Suite 1801 Dallas, Texas 75201 Tel.: (214) 583-2233 Fax: (214) 583-2234 jgoldfarb@goldfarbpllc.com . .. . . .,, ..

TO THE HONORABLE COURT OF APPEALS:

Pursuant to Rule 10.5(c) of the Texas Rules of Appellate Procedure, Appellant

Martin L. Graman ("Appellant") seeks a postponement of oral argument in this case.

In support of this Motion, Appellant would respectfully show the Court the

following:

1. Oral argument is currently set on December 15, 2015 at 10:00 a.m.

2. Appellant seeks a postponement of oral argument to a later date.

3. Counsel for Appellant seeks to postpone the oral argument due to

demands placed on him by other matters, namely: Counsel Jeffrey Goldfarb is set

for a day-long evidentiary hearing in Florida state court in Miami, Florida on

December 14, 2015.

4. This Motion is not being filed for purposes of delay, but rather so that

justice may be done in this case.

5. This Motion is agreed to by all parties.

PRAYER

Appellant Martin L. Graman respectfully asks the Court grant this Motion and

postpone oral argument set for December 15, 2015 at 10:00 a.m. to a later date.

APPELLANT'S UNOPPOSED MOTION TO POSTPONE ORAL ARGUMENT Page2 •' '" .

Dated: October 20, 2015 Respectfully submitted,

By: Isl Jeffrey Goldfarb Jeffrey Goldfarb State Bar No. 00793820 GOLDFARB PLLC Saint Ann Court 2501 N. Harwood Street, Suite 1801 Dallas, TX 75201 Phone: 214.583.2333 Fax: 214.583.2234 jgoldfarb@goldfarbpllc.com

ATTORNEYS FOR APPELLANT MARTIN L. GRAMAN

APPELLANT'S UNOPPOSED MOTION TO POSTPONE ORAL ARGUMENT PageJ CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with W. "Trey" R. Dyer, III, counsel for Appellee Jason L. Graman, regarding the relief sought in this Motion. Mr. Dyer stated that his client was unopposed to the relief sought herein.

Isl Jeffrey Goldfarb Jeffrey Goldfarb

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been served on the following counsel in accordance with the Texas Rules of Civil Procedure on October 20, 2015:

W. "Trey" R. Dyer III CHERRYPETERSENLANDRY ALBERTLLP 8350 North Central Expressway Suite 1500 Dallas, Texas 75206-1632

APPELLANT'S UNOPPOSED MOTION TO POSTPONE ORAL ARGUMENT Page4