Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 2/4/2015 5:10:35 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-13-01064-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 2/4/2015 5:10:35 PM CHRISTOPHER PRINE CLERK NO. 01-13-01064-CV
IN THE FIRST COURT OF APPEALS
HOUSTON, TEXAS HANDS OF HEALING RESIDENTIAL TREATMENT CENTER, INC.
AND ALL OTHER OCCUPANTS,
Appellant, V.
JOHN HAVENAR,
Appellee. UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLY BRIEF OF APPELLANT TO THE HONORABLE FIRST COURT OF APPEALS:
Pursuant to T EX . R. A PP . P. 10.1 and 38.6(d), the Appellant, Hands of Healing
Residential Treatment Center, Inc. and all Occupants, files this Unopposed Motion to
Extend Time to File Reply Brief of Appellant.
Appellee filed its Brief on October 16, 2014, a day after the brief was required to
be filed. As background Appellee’s brief was due on July 2, 2014.
Counsel for Appellant requests an extension to February 6, 2015, to file its Reply
Brief. The extension is necessary because of the holidays and four other briefing
deadlines in other cases that made it difficult for Appellant to file a Reply Brief shortly
after its motion to strike was denied on October 23, 2014.
On January 10, 2015, the parties were notified that there would be no oral
argument in the case and that this case would be submitted to the panel of judges on
February 25, 2015. As such, the extension would not likely interfere with the court’s
schedule.
Counsel for Appellant seeks this extension of time to be able to prepare a cogent
and succinct Reply Brief to aid this Court in its analysis of the issues presented. This
request is not sought solely for delay but in the interest of justice. Opposing counsel is
not opposed to this extension.
All facts recited in this motion are within the personal knowledge of the counsel
signing this motion; therefore, no verification is necessary under Rule of Appellate
Procedure 10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this
Unopposed First Motion to Extend Time to File Appellant’s Brief and extend the
Deadline for Filing the Appellant’s Reply Brief up to and including February 6, 2014.
Appellant requests all other relief to which it may be entitled.
Respectfully submitted, /s/ Victoria Plante-Northington Texas Bar No. 00798436 PLANTE LAW FIRM, P.C.
5177 Richmond Ave., Suite 1275 Houston, Texas 77056 Telephone: (713) 526-2615 Counsel for Appellant *3 C ERTIFICATE OF C ONFERENCE
I certify that I conferred with counsel for Appellee regarding this motion and that
Appellee is not opposed to this motion.
/s/ Victoria Plante-Northington C ERTIFICATE OF S ERVICE
I certify that on February 4, 2015, I have sent a copy of this motion to the
following counsel by email, U.S. mail, and/or facsimile:
Michael R. Wadler
Harberg Huvard Jacobs Wadler, LLP
2100 West Loop South, Suite 110
Houston, Texas 77027-3534
Counsel for Appellee
/s/ Victoria Plante-Northington VICTORIA PLANTE-NORTHINGTON