Rajinder Singh, Rita Kaur, Rajiv Chhabra and Gauri Chhabra v. Slawomir J. Skibicki and a & Skipol, Inc.

Opinion

ACCEPTED

01-14-00825-cv

FIRST COURT OF APPEALS

HOUSTON, TEXAS

3/20/2015 12:10:06 AM

CHRISTOPHER PRINE

CLERK

01-14-00825-CV

FILED IN

__________________________________ 1st COURT OF APPEALS HOUSTON, TEXAS 3/20/2015 12:10:06 AM

IN THE

CHRISTOPHER A. PRINE

COURT OF APPEALS FOR THE Clerk FIRST JUDICIAL DISTRICT OF TEXAS AT HOUSTON, TEXAS

____________________________________

RAJINDER SINGH AND RITA KAUR, RAJIV CHHABRA AND GAURI CHHABRA,

APPELLANTS

VS.

SLAWOMIR J. SKIBICKI AND A & SKIPOL, INC., A TEXAS CORPORATION,

APPELLEES

Appealed from the 11TH DISTRICT COURT of Harris County, Texas

Trial Court Cause No. 2013-76488

_______________________________________

APPELLANTS’ SECOND MOTION TO EXTEND TIME FOR FILING APPELLANT’S BRIEF

_______________________________________

TO THE HONORABLE JUSTICES OF SAID COURT:

COMES NOW the Appellants, RAJINDER SINGH AND RITA KAUR and

files this their SECOND Motion to Extend Time for Filing Appellant’s Brief and

would respectfully show the following:

1. Appellant’s brief per the courts order is March 20, 2015(30 days after the

later of either the date of the clerk’s record filed or the date of the reporter’s record

filed.)

2. The complete record was filed on February 17, 2015

3. The courts online calendar indicates the deadline was on March 17, 2015.

4. No rule provides a deadline to file this motion to extend. See Tex. R. App.

P. 38.6(d).

5. Although mediation was ordered, neither party has mediated at this time.

6. It is unclear as to the reason the online deadline contradicts the Rules, the

Court’s Order, and the Notice, however Appellants file this motion in abundance

of caution. Appellants respectfully request the deadline for filing their brief be set

for March 20, 2015, which is thirty days for the date the complete record was filed.

7.Contemporaneously with filing this Motion, Appellants are also filing their

Brief.

WHEREFORE PREMISES CONSIDERED, APPELLANTS, RAJINDER

SINGH and RITA KAUR , pray that this Court extend the time in which to file

their Brief and accept Appellants Brief, file contemporaneously with this motion as

timely filed.

Respectfully submitted,

_____________________________

“DANIEL” CHUNG LEE

State Bar No. 24053793

C.Y. Lee Legal Group, PLLC 1305 Prairie St. Ste 300

Houston, Texas 77002

T: (682)551-8506 F: (713)223-0755

cyleelaw@gmail.com

ATTORNEYS FOR Rajinder Singh and Rita Kaur

CERTIFICATE OF CONFERENCE

Jeremy Roberts, counsel for Appellees who states that he is opposed to this motion.

Dated this 20th day of March, 2015.

_________________________________

“Daniel” Chung Lee

CERTIFICATE OF SERVICE

I hereby certify that on this date a true and correct copy of the foregoing document was served upon all parties through their attorneys of record, with said service being effectuated by the following method:

___ Certified Mail, Return Receipt Requested ___ Telecopy X Eservice ___ Hand Delivery ___ Regular Mail, Postage Prepaid

Dated this 20th day of March, 2015.

_________________________________

“Daniel” Chung Lee