Ronny Puga and Rickey Puga v. Barbara Salesi

• Court: Court of Appeals of Texas
• Decided: January 9, 2015
• Docket: 01-14-00724-CV
• Status: Published

Opinion

ACCEPTED 01-14-00724-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 1/9/2015 2:34:14 PM CHRISTOPHER PRINE CLERK

IN THE

FIRST COURT OF APPEALS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 1/9/2015 2:34:14 PM ______________________________ CHRISTOPHER A. PRINE Clerk NO. 01-14-00724-CV

_____________________________

RONNY PUGA AND RICKEY PUGA, Appellants

v.

BARBARA SALESI, Appellee

_________________________

On Appeal from the 133rd Judicial District Court of Harris County, Texas Trial Court Cause No. 2011-28575

__________________________________________

Richard L. Petronella Petronella Law Firm, P.C. SBN 15852000 2421 Tangley, Suite 116 Houston, Texas 77005 Phone 713.965.0606 Fax 713.965.0676 Email richard@petronellalawfirm.com

Appellants’ Attorney APPELLANTS’ FIRST MOTION TO EXTEND TIME TO FILE APPELLANTS’ BRIEF

COMES NOW RONNY PUGA AND RICKEY PUGA, Appellants,

and file this First Motion to File Appellants’ Brief.

1. Appellants filed this appeal on August 29, 2014.

2. On October 10, 2014, the Clerk’s Record was filed with this

Court.

3. On December 16, 2014, the Court Reporter’s Record was filed

with this Court.

4. On December 22, 2014, the Court Reporter’s Supplemental

Record was filed with this Court which contained the record of the second

day of a three day trial in the trial court and most of the relevant evidence.

5. The Appellants’ Brief is now due on January 15, 2015.

6. This is the Appellants’ first motion to extend the time to file

Appellants’ Brief.

7. Appellants’ appellate counsel was not Appellants’ trial counsel

so he was not already familiar with the facts and legal issues below but he

has been diligently reviewing the record below to prepare Appellants’ Brief.

There is not sufficient time before January 15, 2015, for Appellants to

adequately prepare their brief. Now, after review of the record below,

2 Appellants’ will request the trial court clerk by letter to supplement the

Clerk’s Record with matters Appellants believe relevant to this appeal.

8. Appellants respectfully request that this Court grant Appellants

a 30 day extension to file Appellants’ Brief.

9. Certificate of Conference. Counsel for Appellants has

conferred with counsel for Appellee, BARBARA SALESI, now the

ESTATE OF BARBARA SALESI, DECEASED, regards this motion, and

this motion is opposed.

Wherefore, premises considered, Appellants respectfully request that

the deadline to file Appellants’ Brief be extended to February 16, 2015.

Respectfully submitted,

PETRONELLA LAW FIRM, P.C.

[s] Richard L. Petronella Richard L. Petronella SBN 15852000 2421 Tangley, Suite 116 Houston, Texas 77005 Phone 713.965.0606 Fax 713.965.0676 richard@petronellalawfirm.com

Attorney for Appellants

3 CERTIFICATE OF SERVICE

I, the undersigned, do hereby certify that I served counsel for Appellee with this pleading by electronic service on January 9, 2015 to:

Dax Faubus Courtney Culver 1001 Texas Avenue, 11th Floor Houston, Texas 77002 Counsel for Appellee

[s] Richard L. Petronella Richard L. Petronella