Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 8/3/2015 12:38:58 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00529-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 8/3/2015 12:38:58 PM CHRISTOPHER PRINE CLERK No. 01-15-00529-CV IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS AT HOUSTON NACE INTERNATIONAL, Appellant v.

MAURICE JOHNSON AND E&M ENTERPRISES, INC.,

Appellees Appealed from the 215 th Judicial District Court Harris County, Texas APPELLEES’MOTION TO EXTEND TIME TO FILE APPELLEES’S BRIEF

Grealish & McZeal, PC ATTORNEYS FOR APPELLEESES, Maurice Johnson & E&M Enterprises, Inc.

TO THE HONORABLE FIRST COURT OF APPEALS:

Appellees respectfully requests this Court to extend the time in which to file Appellees’

Brief. NACE International, is the Appellant. Maurice Johnson & E&M Enterprises, Inc. are the

Appellees. Appellees’ Brief is due August 3, 2015. However, Appellees seek a 20 day extension

to file brief under the authority of T.R.A.P. 10.5(b).

The Court may extend time to file Appellees’ Brief under the authority of Texas Rules of

Appellate Procedure 10.5(b). This is Appellees’ first request for extension. Appellees seek an

extension of time to file Appellees’ Brief because the lead briefing attorney recently finished

closing a large corporate acquisition and there was not sufficient time to adequately, effectively

and diligently prepare Appellees’ Brief before the August 3, 2015 brief due date.

This is Appellees’ first request for an extension of time and Appellant, NACE

International by and through its attorney was unavailable to determine if it was opposed.

For the foregoing reasons, Appellees, Maurice Johnson & E&M Enterprises, Inc., request

this Court grant an extension of time in which to file his brief to on or about, August 24, 2015.

Respectfully Submitted, GREALISH & McZEAL, PC BY: /s/ Marcellous S. McZeal *3 CERTIFICATE OF SERVICE I hereby certify that on this the 3 rd day of August 2015, a copy of the attached

Motion was forwarded to the counsel below via certified mail return receipt requested

pursuant to province of T EX .R.C IV .P. 21a

/s/ Marcellous S. McZeal via facsimile @ (713) 535-5533

Robert Naudin

John L. Grayson

Cokinos, Bosien & Young

Four Houston Center

1221 Lamar, 16th Floor

ATTORNEYS FOR APPELLANT

CERTIFICATE OF CONFERENCE I hereby certify that I have made a good faith effort to confer with Appellant’s

counsel on August 3, 2015. I unsuccessfully telephoned and emailed Mr. Naudin, counsel

for Appellant, to determine if he was opposed to this motion. At the time of the filing of

this Motion, there was no response.

/s/ Marcellous S. McZeal Marcellous McZeal