Michael Justin Jacobs v. Adana Alt

• Court: Court of Appeals of Texas
• Decided: February 17, 2015
• Docket: 14-15-00028-CV
• Status: Published

Opinion

ACCEPTED 14-15-00028-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/16/2015 5:39:13 PM CHRISTOPHER PRINE CLERK

NO. 14-15-00028-CV

FILED IN 14th COURT OF APPEALS IN THE FOURTEENTH COURT OF APPEALS, HOUSTON, TEXAS HOUSTON, TEXAS 2/17/2015 9:15:00 AM CHRISTOPHER A. PRINE Clerk

MICHAEL JUSTIN JACOBS,

APPELLANT

V.

ADANA ALT,

APPELLEE

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

Pursuant to Rule 38.6(a) and Rule 10.5(b) of the Texas Rules of Appellate

Procedure, Michael Justin Jacobs, the Appellant in this proceeding, seeks an

extension of the deadline for filing his Appellant’s Brief with this Court. In

support of his request for an extension of time, Michael Justin Jacobs submits the

following:

1. In compliance with Rule 10.5(b) of the Texas Rules of Appellate

Page 1 of 4 Procedure, Appellant’s counsel advises this Court of the following matters:

(A) Appellant’s Brief is due to be filed with the Clerk of this

Court on February 26, 2015.

(B) Appellant is seeking an extension of time for filing his Appellant’s

Brief from February 26 2015 until March 28, 2015 (30 days).

(C) the number of previous extensions granted regarding the

item in question - None

(D) the facts reasonably relied on to reasonably explain the

need for an extension are described below.

2. The undersigned counsel has had numerous other commitments,

including hearings, mediations, and discovery deadlines, that have prevented

counsel from preparing a working draft of Appellant’s Brief to date. Additionally,

the undersigned counsel has a full-day deposition and a two-day trial scheduled

during the ten days that, along with witness and trial preparation, make timely

preparation of the Appellant’s Brief impossible.

3. The undersigned counsel respectfully represents to this Court that

additional time is needed to properly brief and explain the issues in a clear and

concise manner.

4. All facts stated herein are within the personal knowledge of the

Page 2 of 4 undersigned counsel.

WHEREFORE, ABOVE PREMISES CONSIDERED, the undersigned

counsel on behalf of Michael Justin Jacobs respectfully prays that upon

consideration of the matters set forth herein, this Court extend the deadline for

filing of the Appellant’s Brief to March 28, 2015.

Michael Justin Jacobs also respectfully prays for such other and further relief

to which he may be justly entitled.

Respectfully submitted,

FRANKENBERRY LAW FIRM 4425 S. Mopac Expressway, Suite 105 Austin, Texas 78735 512-252-9937 Fax: 512-852-5937 paige@frankenberrylaw.com

By: ______________________________ Paige Frankenberry State Bar No.: 24074226

ATTORNEY FOR APPELLANT, MICHAEL JUSTIN JACOBS

CERTIFICATE OF CONFERENCE

Pursuant to Rule 10.1(a)(5) of the Texas Rules of Appellate Procedure, the undersigned counsel advises this Court that prior to making this request, she contacted Appellee’s attorney of record, Robert D. Ettinger, about the merits of the motion, and he does not oppose Appellant’s Motion for Extension of Time.

Page 3 of 4 _________________________ Paige Frankenberry

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been served on opposing counsel, Robert D. Ettinger, P.O. Box 50323, Austin, Texas 78763 via email to robert@ettlaw.com on this 17th day of February, 2015.

__________________________ Paige Frankenberry

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