Michael Queen and Ian Magee v. RBG USA, Inc.

Opinion

ACCEPTED 14-14-00829-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/6/2015 3:09:04 PM CHRISTOPHER PRINE CLERK

No. 14-14-00829-CV

FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS IN THE COURT OF APPEALS FOR THE 7/6/2015 3:09:04 PM CHRISTOPHER A. PRINE FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS Clerk HOUSTON, TEXAS

MICHAEL QUEEN and IAN MAGEE, Appellants/Cross Appellees,

v.

RBG USA, Inc., Appellee/Cross Appellant.

On appeal from the 268th Judicial District Court of Fort Bend County, Texas

JOINT MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE AND REPLY BRIEFS

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

Appellants Michael Queen and Ian Magee (collectively, “Appellants”) and

Appellee RBG USA, Inc. (“Appellee”) (Appellants and Appellee are collectively

referred to as the “Parties”), in the above-styled and numbered cause, file this Joint

Motion for Extension of Time to File Responsive and Reply Briefs and request that

the Court enter an order extending the time for the filing of their Responsive Briefs

with the Court through, and including June 15, 2015, and for the filing of their Reply Briefs, if any, with the Court through, and including August 4, 2015, and in

support thereof would respectfully show the following:

1. The Parties’ current deadline to file their Responsive Briefs is July 8,

2015.

2. The Parties’ current deadline to file their Reply Briefs, if any, is July

28, 2015.

3. The Parties’ counsels need additional time to prepare their Responsive

and Reply Briefs because of their professional and personal schedules.

4. This is the Parties’ first request for an extension of time to file their

Responsive and Reply Briefs. This motion is not sought for delay but so that

justice may be done.

WHEREFORE, PREMISES CONSIDERED, the Parties respectfully pray

that the Court grant their Joint Motion for Extension of Time to File Responsive

and Reply Briefs and extend the time for them to file their Responsive Briefs

through, and including, July 15, 2015, and extend the time for them to their Reply

Briefs, if any, through, and including August 4, 2015.

[signatures on following page] Respectfully submitted,

/s/ Stephen J. Schechter1 /s/ Michael R. Rahmn Stephen J. Schechter Craig D. Dillard State Bar No. 17735512 State Bar No. 24040808 STEPHEN J. SCHECHTER, P.C. Michael R. Rahmn P.O. Box 792 State Bar No. 24074924 Boerne, Texas 78006 GARDERE WYNNE SEWELL LLP Telephone: (830) 249-3500 1000 Louisiana, Suite 3400 Facsimile: (830) 249-8500 Houston, Texas 77002-5007 stephen@sjs-pc-law.com Telephone: (713) 276-5500 Facsimile: (713) 276-5555 ATTORNEY-IN-CHARGE FOR cdillard@gardere.com APPELLANTS MICHAEL QUEEN mrahmn@gardere.com AND IAN MAGEE ATTORNEYS FOR APPELLEE RBG USA, INC.

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Joint Motion for Extension of Time to File Briefs has been served on Appellants’ attorney of record on July 6, 2015.

/s/ Michael R. Rahmn Michael R. Rahmn

1 With permission

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