Case Information

*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 7/9/2015 2:07:15 PM LISA MATZ Clerk *1 ACCEPTED 05-13-01024-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 7/9/2015 2:07:15 PM LISA MATZ CLERK CAUSE NO. 05-13-01024-C

MICHELLE KIM § IN THE COURT OF APPELAS

Appellant and Counter-Appellee, §

§ § VS. § FIFTH DISTRICT OF TEXAS

§ § KUM SUN HENDRICKSON §

Appellee and Counter-Appellant. § AT DALLAS, TEXAS

APPELLEE AND COUNTER-APPELLANT’S MOTION TO EXTEND TIME TO FILE

MOTION FOR RE-HEARING

TO THE HONORABLE COURT OF APPEALS:

COMES now Kum Sun Hendrickson, Appellee and Counter-Appellant, pursuant to Rules

49.1, 49.8, and 10.5(b), Texas Rules of Appellate Procedure, and would show the following:

CERTIFICATE OF CONFERENCE

1. Appellee’s counsel did confer with Appellant’s counsel two days ago considering this

motion, and he was of the opinion that the time deadline for this motion had already

expired; however, Appellee’s counsel learned that the deadline was not 10 days but 15

days from the rendition of the judgment.

2. It is presumed that Appellant’s counsel is opposed to this motion.

I. GROUNDS FOR MOTION

3. Judgement was rendered on June 25, 2015.

4. The deadline to file a motion for re-hearing is fifteen (15) days thereafter, or July 10,

2015.

5. Within that period of time, this motion is timely filed and seeks an extension of time for

the reason that Appellee’s counsel is currently in the hospital and is not expected to

return to practice for a minimum of 2 weeks.

6. There have been no previous requests to extend time to file a motion for re-hearing.

7. Counsel for Appellee will provide medical proof thereof if requested by this court.

II. REQUESTED RELIEF

8. Appellee request until July 31, 2015 to file a motion for re-hearing.

9. Appellee requests that this motion be granted and for general relief.

Respectfully submitted, THE LINE LAW FIRM 6220 Gaston Avenue, Suite 609 Dallas, Texas 75214 214-821-2882 (Office – Main) 214-682-0880 (Direct) 214-821-2882 (Fax) By: ______________________________

David K. Line, Attorney at Law SBN: 12385500 *3 C ERTIFICATE OF SERVICE

I, the undersigned attorney, do hereby certify that a true and correct copy of the foregoing

pleading has been served upon all counsel of record in accordance with Rule 21a, Texas Rules of

Civil Procedure, to-wit:

Emil Lippe

Attorney for Appellant

600 N. Pearl Street

Suite S2460

Dallas, Texas USA 75201

View Map to our location

Telephone: (214) 855-1850

Facsimile: (214) 720-6074

E-mail: emil@texaslaw.com

Via: Fax and E-mail Date: January 27, 2014

___________________________________ David Line, Attorney