Peter D. Tran, Nam Van Nguyen, the Kim Hoang and Tuyen Ngoc Bui, on Behalf of the Vietnamese Community of Houston & Vicinity, Inc. a Non-Profit Corporation v. Aloysius Duy-Hung Hoang, Teresa Ngoc-Bich Hoang, Cavatina Truong, Skybird Nguyen and Hoc Nhu Phan

• Court: Court of Appeals of Texas
• Decided: May 4, 2015
• Docket: 01-14-00973-CV
• Status: Published

Opinion

ACCEPTED 01-14-00973-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 5/4/2015 2:18:47 PM CHRISTOPHER PRINE CLERK

NO. 01-14-00973-CV

PETER D. TRAN, NAM VAN IN THE FIRST FILED IN NGUYEN, THE KIM HOANG, 1st COURT OF APPEALS HOUSTON, TEXAS AND TUYEN NGOC BUI 5/4/2015 2:18:47 PM ON BEHALF OF THE CHRISTOPHER A. PRINE VIETNAMESE COMMUNITY OF Clerk HOUSTON & VICINITY, INC., Appellants,

VS. COURT OF APPEALS

ALOYSIUS DUY-HUNG HOANG, TERESA NGOC-BICH HOANG, CAVATINA TRUONG, SKYBIRD NGUYEN AND HOC NHU PHAN, Appellees. HOUSTON, TEXAS

APPELLANTS' MOTION TO EXTEND TIME TO FILE BRIEF

Appellants ask the Court to extend the time to file their brief.

A. Introduction

1. Appellants are Peter D. Tran, Nam Van Nguyen, The Kim Hoang, and Tuyen

Ngoc Bui on Behalf of the Vietnamese Community of Houston & Vicinity, Inc.

2. This Motion to Extend Time to File Brief is brought pursuant to Rule 10.5(b)

of the Texas Rules of Appellate Procedure.

B. Argument & Authorities

3. The Court has the authority under Texas Rule of Appellate Procedure 10.5(b)

to extend the time to file the brief.

4. Appellants request an additional 7 days to file their brief, extending the time

until May 11, 2015.

1 5. Three previous extensions have been requested and granted to extend the time

to file Appellants' brief.

6. Appellants need additional time to file their brief because Appellants' counsel

has been involved in multiple state district court cases and mediations. Additionally,

Appellants' counsel lost his paralegal to another firm and has not found a suitable

replacement requiring counsel to undertake all legal work without assistance.

Appellants' counsel requires additional time to complete the drafting of the brief.

C. Conclusion

7. Appellants require additional time to complete their brief.

D. Prayer

8. For these reasons, Appellants ask the Court to grant an extension of time to

file their brief until May 11, 2015.

Respectfully submitted,

ALLAN A. CEASE & ASSOCIATES, P.C.

/s/ Allan A. Cease

BY: Allan A. Cease Texas Bar No. 04040550 Email: allancease@comcast.net 56 Sugar Creek Center Blvd, Suite 300 Sugar Land, Texas 77478 Tel. 281-980-0909 Fax 281-980-1069 Attorney for Appellants, Peter D. Tran, Nam Van Nguyen, The Kim Hoang, and Tuyen Ngoc Bui on Behalf of the Vietnamese Community of Houston & Vicinity, Inc.

2 VERIFICATION

STATE OF TEXAS

FORT BEND COUNTY §

Before me, the undersigned notary, on this day personally appeared Allan A.

Cease, the affiant, a person whose identity is known to me. After I administered an

oath to affiant, affiant testified:

"My name is Allan A. Cease. I am capable of making this verification. I have

read the Appellants' Motion to Extend Time to File Brief. The facts stated in it are

within my personal knowledge and are true and correct."

Allan A. Cease

SWORN TO AND SUBSCRIBED BEFORE ME by Allan A. Cease on May 4, 2015.

,,,,,,,,,, /6%*tt:s * %si Notary ANNIE NGUYEN Public. State of Texas :,,z My Commission Expires Notary Public - St. Texas ,;;,,POrW ' ,,,,,,,,,,, April 17, 2019

3 CERTIFICATE OF CONFERENCE

I certify that I have conferred with Brent C. Perry and he is unopposed to this

motion.

CERTIFICATE OF SERVICE

I certify that a copy of Appellants' Motion to Extend Time to File Brief was

served on Appellees, Aloysius Duy-Hung Hoang, Teresa Ngoc-Bich Hoang, Cavatina

Truong, Skybird Nguyen and Hoc Nhu Phan, through counsel of record, Brent C.

Perry, at 800 Commerce Street, Suite 102, Houston, Texas 77002, by email to

brentperry@brentperrylaw.com, on May 4, 2015.