Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/29/2015 1:55:20 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00930-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/29/2015 1:55:20 PM CHRISTOPHER PRINE CLERK NO. 01-15-00930-CV IN THE COURT OF APPEALS FIRST DISTRICT OF TEXAS HOUSTON, TEXAS Harris County, Texas, Appellant, v .

Stephanie Jo Baker, Appellee ________________________________________________________________

ON APPEAL FROM THE 295 TH JUDICIAL DISTRICT COURT

OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2014-02549 APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME

_________________________________________________________________

Tritico Rainey, P.L.L.C.

L. JAMES KRELL

State Bar No. 24072191

RON S. RAINEY

State Bar No. 16484425

1523 Yale Street

Houston, Texas 77008

(713) 581-3399

(713) 581-3360 (Facsimile) ATTORNEYS FOR APPELLEE *2 TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW, STEPHANIE JO BAKER, Appellee herein, by and through

their undersigned counsel, and files this Appellees’ Unopposed Motion for

Extension of Time to File her Appellee’ Brief in compliance with Rules 38.6(d)

and 10.5 of the Texas Rules of Appellate Procedure. In support of this motion,

Appellant would show as follows:

(a) After receiving an extension, Appellants’ brief was filed on December

16, 2015.

(b) Appellee requests an extension of fourteen (14) days, until January 18,

2016 to prepare her brief.

(d) This is Appellee’s first request and/or motion for an extension of time.

(e) Appellee is requesting this extension so that she might adequately

brief the issues in dispute in this case, and it is not sought for the

purpose of an improper delay.

(f) the undersigned has conferred with counsel for the Appellant, and the

Appellant is unopposed to this motion.

Appellants allege good cause exists for this request due to the undersigned’s

litigation and appellate schedule. The undersigned is currently assisting in both

criminal and civil matters at the trial and appellate level for his firm, Tritico

Rainey, PLLC. Moreover, while assisting in the drafting and preparation of these

appeals, the undersigned is also maintaining a litigation practice throughout the

state of Texas

WHEREFORE, PREMISES CONSIDERED, Appellants respectfully

request that this Honorable court grant an extension of fourteen (14) days, up to

and including, Monday, January 18, 2016, to file Appellee’s brief.

Respectfully submitted, TRITICO RAINEY, PLLC By: /s/ L. James Krell L. JAMES KRELL State Bar No. 24072191 RON S. RAINEY State Bar No. 16484425 1523 Yale Street Houston, Texas 77008 (713) 581-3399 (713) 581-3360 (Facsimile) ATTORNEYS FOR APPELLEE *4 CERTIFICATE OF CONFERENCE I hereby certify that on December 29, 2015, I conferred with Keith Toler,

counsel for Appellant, by email regarding this motion. He indicated to me that he

was unopposed to this motion,

/s/ L. James Krell L. James Krell CERTIFICATE OF SERVICE Pursuant to Rule 9.5(b)(1) of the Texas rules of Appellate Procedure, I do

hereby certify that if the email address for counsel of record for the Appellee is on

file with the electronic filing manager, then a true and correct copy of the

foregoing pleading was served electronically through the electronic filing manager.

In addition, I do hereby certify that a true and correct copy of the foregoing

pleading was served by facsimile to Mr. Keith Toler, on the 29 th day of December,

2015.

/s/ L. James Krell L. James Krell