Richard Saad, Jr. v. Vriselda R. Valdez

• Court: Court of Appeals of Texas
• Decided: December 10, 2015
• Docket: 14-15-00845-CV
• Status: Published

Opinion

ACCEPTED 14-15-00845-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/10/2015 4:43:53 PM CHRISTOPHER PRINE CLERK

No. 14-15-00845-CV

IN THE COURT OF APPEALS FILED IN 14th COURT OF APPEALS FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS HOUSTON, TEXAS AT HOUSTON 12/10/2015 4:43:53 PM CHRISTOPHER A. PRINE Clerk

RICHARD SAAD, JR. Appellant,

V.

VRISELDA R. VALDEZ, ET AL. Appellee __________________________________________________________________

On Appeal from the 234th Judicial District Court of Harris County, Texas Cause No. 2011-17650 __________________________________________________________________

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

Robert J. Killeen, Jr. State Bar No. 11407000 Robert C. Stern State Bar No. 24053637 Gerald M. Johnson, III State Bar No. 10722580 KILLEEN & STERN, P.C. 1811 Bering, Suite 120 Houston, Texas 77057 713.626.5100-telephone 713.626.4545-facsimile rkilleen@killeen-law.com Counsel for Appellant, Richard Saad, Jr.

TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS:

Appellant, Richard Saad, Jr., files this unopposed motion for extension of

time to file its brief on the merits. The current filing deadline for the brief is

December 14, 2015. Appellant requests a 30-day extension, for a new deadline of

January 13, 2016.

The reasons for this extension are that counsel for Appellant is also tasked

with (1) preparing an appellant’s brief in 09-15-00299-CV, National Security Fire

& Casualty Co., v. Rene Lampson and Justina Henriquez, in the Court of Appeals

for the Ninth Judicial District; filed July 30, 2015; (2) preparing an appellant’s

brief in 14-15-00714-CV, National Security Fire & Casualty Co., v. Ozier Hurst,

in the Court of Appeals for the Fourteenth Judicial District; filed August 21, 2015;

and (3) preparing an appellant reply brief in 14-15-00610-CV, South Winds

Express Construction, LLC v. D.H. Griffin of Texas, Inc., in the Court of Appeals

for the Fourteenth Judicial District, filed July 2, 2015.

No previous extensions have been granted, and the Court has authority to

extend the time to file a brief under Texas Rule of Appellate Procedure 38.6(d).

This extension is unopposed and is not sought for delay only. No party will be

prejudiced if it is granted. As set forth in the Certificate of Conference, Appellee

does not oppose the relief sought by this motion.

For these reasons, Appellant, Richard Saad, Jr., prays that this Court grant

his Unopposed Motion for Extension of Time to File Reply Brief on the Merits,

extending the deadline to January 13, 2016.

Respectfully submitted,

KILLEEN & STERN, P.C.

By: /s/ Robert J. Killeen, Jr. Robert J. Killeen, Jr. Texas Bar No. 11407000 E-mail: rkilleen@killeen-law.com Robert C. Stern Texas Bar No. 24053637 E-mail: rstern@killeen-law.com Gerald M. Johnson, III State Bar No. 10722580 E-mail: tjohnson@killeen-law.com 1811 Bering Dr., Suite 120 Houston, Texas 77057 Office: (713) 626-5100 Fax: (713) 626-4545

ATTORNEYS FOR APPELLANT, RICHARD SAAD, JR.

CERTIFICATE OF CONFERENCE

On December 10th, 2015, the undersigned conferred with counsel for Appellee, who stated that his client does not oppose the relief requested in this motion.

/s/ Robert J. Killeen, Jr. Robert J. Killeen, Jr.

CERTIFICATE OF SERVICE

On December 10, 2015 I electronically filed this First Unopposed Motion for Extension of Time to File Brief with the Clerk using the eFile.TXCourts.gov electronic filing system which will send notification of such filing to the following:

Hugh J. Plummer Plummer and Farmer 3303 Louisiana Street, Suite 145 Houston, Texas 77006 Via Email: pplummer@plummerandfarmer.com

ATTORNEY FOR APPELLEE VRISELDA R. VALDEZ, ET AL.