Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/2/2015 3:19:43 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00927-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/2/2015 3:19:43 PM CHRISTOPHER PRINE CLERK No. 14-14-00927-CV
In The
Fourteenth Court of Appeals at Houston, Texas ULRIKA BJORKSTAM AND JOSEPH DANIEL DRAY,
Appellants, v.
WOODWARD, INC.,
Appellee.
On Appeal from the 190 th Judicial District Court Of
Harris County, Texas
Trial Cause No. 2010-31214
The Honorable Patricia J. Kerrigan, Presiding
SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANTS’ BRIEF
Ulirka Bjorkstam and Joseph Daniel Dray file their Second Unopposed
Motion for Extension of Time to File Appellants’ Brief, pursuant to Tex. R. App.
P. 10.5(b).
1. Presently, Appellants’ Brief is due March 2, 2015.
2. Through this Unopposed Motion, Appellants seek an extension of
twenty-one (21) days to file their Brief. Should the Court grant this Motion, the
new deadline will be March 23, 2015.
3. Contemporaneously with this Motion, Appellants filed their
Unopposed Motion to Supplement the Reporter’s Record. Through that Motion,
Appellants seek to add the transcript of a hearing that occurred on May 17, 2013.
There is a reference to the May 17 th hearing in the Reporter’s Record currently on
file with the Court. The May 17 th hearing transcript is necessary for the complete
presentation of Appellants’ arguments. The court reporter is ready to file the May
17 th hearing transcript, if the Court should grant Appellants’ Unopposed Motion to
Supplement the Reporter’s Record.
4. Additionally, Appellants’ counsel argued before the Delaware
Supreme Court on February 18, 2015 in Bell Helicopter Textron, Inc. v. Andres
Arteaga, et al., Case Number 333, 2014. As a result, the first eighteen days of
February were devoted to preparing for this argument, as well as getting
acclimated to a new law firm. Moreover, upon return from Delaware, where the
weather was extremely cold, Appellants’ counsel fought cold and flu symptoms for
several days.
5. Counsel for Woodward, Inc., has no objection to the requested
extension of twenty-one (21) days. Therefore, should the Court grant this Motion,
the extension will not result in undue hardship or material harm to Woodward, Inc.
6. Appellants have previously sought a thirty-day extension from the
Court.
For these reasons, Appellants request that the Court grant their Second
Unopposed Motion for Extension of Time to File Appellants’ Brief.
Respectfully submitted, PIERCE & O’NEILL, LLP Texas State Bar Number 17858450 4203 Montrose Boulevard Houston, Texas 77006 713-634-3607 Direct 713-634-3600 Main 713-634-3601 Facsimile jschwambach@pierceoneill.com Attorney for Appellants *4 CERTIFICATE OF CONFERENCE
I, John C. Schwambach, Jr., counsel for Appellants, Ulrika Bjorkstam and
Joseph Daniel Dray, hereby certify that I have conferred with Timothy S. McConn,
counsel for Appellee, about the merits of this Motion, and he is unopposed to this
Motion.
*5 CERTIFICATE OF SERVICE
Pursuant to the Texas Rules of Appellate Procedure, I hereby certify that a
true and correct copy of the foregoing was electronically filed and served upon all
know counsel of record this 2 nd day of March, 2015.