Santos San Juan D/B/A Santos Wrecker Repair v. Jose Segovia

Opinion

ACCEPTED 14-14-00407-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 9/1/2015 12:15:08 PM IN THE COURT OF APPEALS CHRISTOPHER PRINE CLERK

FOURTEENTH SUPREME JUDICIAL DISTRICT HOUSTON TEXAS FILED IN 14th COURT OF APPEALS JOSE SEGOVIA HOUSTON, TEXAS § 9/1/2015 12:15:08 PM v. § CHRISTOPHER A. PRINE NO. 14-14--00407-CV § Clerk SANTOS SAN JUAN D/B/A SANTOS WRECKER SERVICE §

THIRD MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUDGES OF SAID COURT:

I.

COMES NOW, Santos San Juan d/b/a Santos Wrecker Service, Appellant in

the above entitled and numbered cause, under the authority of Tex. R. App. P. Rules

9 and 10 would respectfully request this Court grant an extension of time to file

Appellant’s Brief and would show the following:

Appellant’s brief is currently due on or about September 1, 2015.

II.

This is Appellant’s third motion for extension of time to file his brief.

III.

Appellant’s attorney, Lawrence F. Cerf, has made significant progress in

reviewing the record and researching the issues. However, this work was juggled

with the attorney’s other work load from other cases and, in fact, he could not take his

designated vacation time as he needed to keep “above water” on his cases. 1 IV.

Accordingly the Appellant asks for a final 45 days to complete and file his

brief.

WHEREFORE, PREMISES CONSIDERED, undersigned counsel prays for

this court to extend the time for filing Appellant’s brief until October 15, 2015 which

is sixty (45) days from the current deadline.

Respectfully submitted,

/S/ Lawrence F. Cerf

________________________________________________ Lawrence F. Cerf Texas Bar Number 04047300 1221 Studewood St. Houston, TX 77008 (713) 520-5949; (713) 426-1202 Fax Lawrencecerf@aol.com ATTORNEY OF APPELLANT

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this Appellant’s MOTION was e mailed to the opposing counsel of record Leonid Kishinevsky at his e mail address of Leo@nielsentriallaw this 1st Day of September, 2015 and said transmission was completed.

____________________________________ Lawrence F. Cef