Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 2:28:00 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00927-cv FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 2:28:00 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 Judicial District Court Of Harris County, Texas Trial Cause No. 2010-31214 The Honorable Patricia J. Kerrigan, Presiding UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANTS’ REPLY BRIEF
Appellants Ulirka Bjorkstam and Joseph Daniel Dray file their Unopposed
Motion for Extension of Time to File Appellants’ Reply Brief, pursuant to Tex. R.
App. P. 10.5(b).
1. Presently, Appellants’ Reply Brief is due July 15, 2015.
2. Through this Unopposed Motion, Appellants seek an extension of
fourteen (14) days to file their Reply Brief. Should the Court grant this Motion,
the new deadline will be July 29, 2015.
3. This Motion is timely, pursuant to Tex. R. App. P. 38.6(d).
4. The requested extension of time is necessary because the undersigned
has a heavy docket, including substantial involvement in the following matters:
Case No. C2012-7881; Jefi Jeannette Ochoa, et al. v. Giti Tire
Corporation, et al. ; in the Superior Court of the State of Arizona in
and for the County of Pima – hearing on Giti Tire (Fujian) Co., Ltd.’s
and Giti Tire Corporation’s Motions to Dismiss for Lack of
Jurisdiction – occurred on July 10, 2015;
Cause No. L-13-0061-CV-B; Texas Crude Energy, LLC and Amber
Harvest, LLC v. Burlington Resources Oil & Gas Company LP ; in the
156 District Court of Live Oak County, Texas – preparation of
Plaintiffs’ Motion for Reconsideration by the Court of Written
Findings and Recommendations of the Master in Chancery with 29
Exhibits that total 679 pages – filed on July 13, 2015.
5. The requested extension is therefore necessary to allow Appellants
adequate time to prepare their Reply Brief. The request for additional time is not
made for delay, but only so that justice may be done.
6. These facts are within personal knowledge of the undersigned.
Therefore, verification is unnecessary. Tex. R. App. P. 10.2.
7. Appellee’s counsel has no objection to the requested extension of
fourteen (14) days. Therefore, should the Court grant this Motion, the extension
will not result in undue hardship or material harm to Appellee.
For these reasons, Appellants request that the Court grant their Unopposed
Motion for Extension of Time to File Appellants’ Reply 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 Terry Adams,
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 15th day of July, 2015.
John Michael Kelly N. Terry Adams, Jr.
(admitted pro hac vice) tadams@bmpllp.com
jkelly@amm-law.com B IERNE , M AYNARD & P ARSONS ,
Gina Marie Diomedi L.L.P. 1300 Post Oak Boulevard, 25 Floor
(admitted pro hac vice)
gdiomedi@amm-law.com Houston, Texas 77056
Christine Marie Niemczyk Telephone: (713) 623-0887
(admitted pro hac vice) Facsimile: (713) 960-1527
cniemczyk@amm-law.com
A DLER M URPHY & M C Q UILLEN LLP
20 South Clark Street, Suite 2500
Chicago, Illinois 60603
Telephone: (312) 345-0700
Facsimile: (312) 345-9860
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