Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 5/1/2015 12:38:16 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00243-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 5/1/2015 12:38:16 PM CHRISTOPHER PRINE CLERK N O . 01-15-00243-CV __________________________________________
I N T HE F IRST C OURT OF A PPEALS
H OUSTON , T EXAS
___________________________________________
T HE D ISCOVERY G ROUP , I NCORPORATED
D / B / A P REFERRED C ORPORATE H OUSING
Appellant
V.
R ICHARD K AMMEN , INDIVIUDALLY
AND D / B / A R ICHARD K AMMEN & A SSOCIATES
Appellee.
___________________________________________
Appeal from the County Civil Court at Law Number Three (3)
Harris County, Texas Trial Court Cause No. 1029597 ___________________________________________
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF
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Andrew P. McCormick Laurie A. Munoz McCormick, Lanza & McNeel, LLP 4950 Bissonnet Street Bellaire, TX 77401 (713) 523-0400 (713) 523-0408 Fax Attorneys for Appellee, Richard Kammen, individually and d/b/a Richard Kammen & Associates *2 UNOPPOSED MOTION TO EXTEND TIME FOR FILING APPELLEE’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
Richard Kammen, individually and d/b/a Richard Kammen & Associates, Appellee,
moves this court to grant an extension of time to file Appellee's Brief, and respectfully
states:
1. Appellee’s Brief is due to be filed with this Court on May 8, 2015.
2. Appellee, Richard Kammen, individually and d/b/a Richard Kammen &
Associates, seeks a 20-day extension of time to file Appellee's Brief, which would make
Appellee's Brief due on or before May 22, 2015.
3 This extension of time is necessary because due to time constraints and the
time required to conduct the research. It will be difficult for counsel for Appellee, Richard
Kammen, individually and d/b/a Richard Kammen & Associates, to adequately prepare the
brief in this appeal if the extension is not granted. Therefore, additional time is needed to
adequately prepare the arguments in this case.
4. Counsel for Richard Kammen, individually and d/b/a Richard Kammen &
Associates has conferred with the counsel for Appellant, The Discovery Group,
Incorporated d/b/a Preferred Corporate Housing, and he is unopposed to the motion to
extend time.
5. This is the first extension of time Appellee has sought for the filing of the
Appellee's Brief.
PRAYER FOR RELIEF For the reasons set forth above, Appellee requests that this court render an order
extending the time for filing Appellee Richard Kammen, individually and d/b/a Richard
Kammen & Associates’s Brief to and including May 22, 2015. Appellee also requests any
other relief to which it may be entitled.
Respectfully submitted, M C C ORMICK , L ANZA & M C N EEL , LLP By: /s/ Andrew P. McCormick ANDREW P. McCORMICK State Bar No. 13457100 amccormick@mlm-lawfirm.com LAURIE A. MUNOZ State Bar No. 24071782 lmunoz@mlm-lawfirm.com 4950 Bissonnet Street Bellaire, Texas 77401 (713) 523-0400 / (713) 523-0408 Attorneys for Appellee Richard Kammen, individually and d/b/a Richard Kammen & Associates CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have
conferred with opposing counsel regarding this request and that Steven D. Poock, counsel
for Appellant, does not oppose this motion.
/s/ Laurie A. Munoz LAURIE A. MUNOZ *4 CERTIFICATE OF SERVICE I certify that I have served this document on all other parties, which are listed below
on May 1, 2015 via email and/or facsimile as follows:
Steven D. Poock
Attorney at Law
P. O. Box 984
Sugar Land, TX 77487
/s/ Laurie A. Munoz LAURIE A. MUNOZ