Case Information
*1 FILED 14-0987 2/19/2015 11:29:51 AM tex-4209022 SUPREME COURT OF TEXAS BLAKE A. HAWTHORNE, CLERK No. 14-0987 IN THE SUPREME COURT OF TEXAS MICHAEL QUINN SULLIVAN, Petitioner, vs.
SALEM ABRAHAM, Respondent. ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR
THE SEVENTH DISTRICT AT AMARILLO NO. 07-13-00296-CV UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONDENT’S RESPONSE LOVELL ATTORNEYS FOR RESPONDENT February 19, 2015 *2 TO THE HONORABLE SUPREME COURT OF TEXAS:
COMES NOW Respondent, Salem Abraham, and files this his Unopposed Motion for Extension of Time to File Respondent’s Response. Respondent would show the Court the following:
I. 1. Respondent Salem Abraham hereby requests an extension of time to file the Respondent’s Response in the above-referenced case. Respondent’s Response is due on Monday, February 23, 2015. Respondent requests a thirty (30) day extension to Wednesday, March 25, 2105, to file his Response. Petitioner’s attorneys do not oppose this motion, nor a thirty (30) day extension.
2. This is Respondent’s first request for an extension. Respondent relies on the following facts as a reasonable explanation for the requested extension of time. Respondent’s counsel, in addition to preparing a Response in this case also had to devote time to a week long jury trial in Vernon, Texas in the matter of John Mikkelsen, acting solely in his capacity as Trustee of the John Mikkelsen Trust v.
Herring Bancorp., Inc., C.C. Burgess and C. Campbell Burgess , Cause No. 24,955, 46 District Court, Wilbarger, Texas, and then, on February 11, 2015, Respondent’s counsel’s wife had an undergo an unexpected surgery. An extension is necessary due to John Lovell’s unexpected schedule changes due to his wife’s surgery and recovery
3. Work on Respondent’s Response began in a timely fashion. However, the
i *3 unplanned matters set out above have made the proper completion of Respondent’s Response by February 23, 2015 a problem.
PRAYER WHEREFORE, PREMISES CONSIDERED, Respondent, Salem Abraham, prays that this Court grant his motion for a thirty (30) day extension of time to file Respondent’s Response.
DATED this 19 day of February, 2015. L OVELL
By:/s/ John H. Lovell John H. Lovell A TTORNEYS FOR R ESPONDENT ii
CERTIFICATE OF CONFERENCE As required by Tex. R. App. P. 10.1(a)(5), I certify that I have conferred with Petitioner’s counsel, Joe Nixon, who indicated that this motion is unopposed.
By:/s/ Courtney D. Miller Courtney D. Miller CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was delivered, as certified below, this 19 day of February, 2015 to:
James E. “Trey” Trainor III Via E-mail and Regular Mail Joseph M. Nixon
B EIRNE M AYNARD P ARSONS LLP
401 W. 15 Street, Suite 845
Austin, Texas 78701
By:/s/ John H. Lovell John H. Lovell iii