Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 6/12/2015 2:40:06 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00088-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 6/12/2015 2:40:06 PM CHRISTOPHER PRINE CLERK NO. 01-15-00088-CV IN THE COURT OF APPEALS

FOR THE FIRST JUDICIAL DISTRICT

OF TEXAS AT HOUSTON ROLAND MOUTON, JR. and DELORIAN MORGAN JONES,

A PPELLANTS V.

CHRISTIAN FAITH MISSIONARY BAPTIST CHURCH, ET. AL.,

A PPELLEES __________________________________________________________________

On Appeal from the 127th Judicial District Court

Harris County, Texas | Cause No. 2012-73452

__________________________________________________________________

MOTION FOR EXTENSION OF TIME TO

FILE APPELLEE’S BRIEF

Appellee, CHRISTIAN FAITH MISSIONARY BAPTIST CHURCH ,

files this motion for extension of time to file its Appellee’s Brief.

1. Applicable Deadlines:

The complete reporter’s record was filed on February 2, 2015. The complete

clerk’s record was filed on March 27, 2015. Appellant’s brief was filed on April

13, 2015. Appellee’s Brief is due on June 12, 2015.

2. Second Request for Extension of Time:

This is Appellee’s second request for an extension of time to file its

Appellee’s Brief. Appellee is asking for a 14-day extension from the date of this

motion to file its Appellee’s Brief, up to and including June 26, 2015 .

3. Legal Authority for Extension of Time:

Pursuant to Texas Rule of Appellate Procedure 38.6(d), this Court is

authorized to extend the time for filing a brief if a motion is filed in conformity

with Texas Rule of Appellate Procedure 10.5, before or after the brief is due. This

request is timely filed.

4. Reasons for Request for Extension of Time:

Counsel for Appellee needs a short amount of additional time to review the

clerk’s record, reporter’s record, and briefing submitted by Appellant in this case,

and to complete its briefing.

PRAYER For the foregoing reasons, Appellee hereby requests that this Court grant an

extension of the deadline to file its Appellee’s Brief by 14 days from the date of

this motion, up to and including June 26, 2015.

*3 Respectfully submitted, L AW O FFICE OF J ANICE L. B ERG /s/ Janice L. Berg Janice L. Berg State Bar No. 24064888 1314 Texas Ave., Suite 1515 Houston, Texas 77002 Tel: 713-993-9100 | Fax: 713-225-0099 Service email: service@janiceberglaw.com Non-service email: janice@janiceberglaw.com ATTORNEY FOR APPELLEE CERTIFICATE OF CONFERENCE

This is to certify that counsel for Appellant, Janice L. Berg, made reasonable

attempts to confer with all parties regarding whether they oppose this motion:

- On June 12, 2015, counsel for Appellee contacted counsel for Appellant,

Nathan Prihoda by email. Mr. Prihoda indicated that he was opposed to the 14-day

extension of time.

/s/ Janice L. Berg Janice L. Berg CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing was served on all

parties or counsel in accordance with the Texas Rules of Appellate Procedure on

June 12, 2015.

/s/ Janice L. Berg Janice L. Berg