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

Opinion

ACCEPTED

01-14-00973-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/21/2015 4:11:01 PM

CHRISTOPHER PRINE

CLERK

NO. 01-14-00973-CV

PETER D. TRAN, NAM VAN § IN THE FIRST FILED IN 1st COURT OF APPEALS

NGUYEN, THE KIM HOANG, § HOUSTON, TEXAS AND TUYEN NGOC BUI § 9/21/2015 4:11:01 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 REPLY BRIEF Appellants ask the Court to extend the time to file their Reply 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 Reply 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 reply brief.

4. Appellants request an additional 4 days to file their reply brief, extending the time until September 25, 2015.

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5. Two previous short extensions have been requested and granted to extend the time to file Appellants' Reply Brief.

6. Appellants need additional time to file their Reply Brief because Appellants'

counsel has been became involved in an emergency filing requiring an emergency temporary orders hearing in the 505th Judicial District Court set for September 22, 2015 at 9:30 a.m. Counsel has had to prepare for the hearing which has taken time away from completion of the Reply Brief. Appellants' counsel requires additional time to complete the drafting of the Reply Brief.

C. Conclusion

7. Appellants require additional time to complete their Reply Brief D. Prayer

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

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file their Reply Brief until September 25, 2015.

Respectfully submitted,

ALLAN A. CEASE & ASSOCIATES, P.C.

e N

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.

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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 Reply 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 September 21, 2015.

••,,,e ANNIE NGUYEN Notary Puatic, State of Texos My CarornistOon Expires of Texas '4%fai ..... Apia 17, 2019

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

af/

Allan A. Cease

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.corn, on September 21, 2015.

ieeN

llan A. Cease

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