Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 6/1/2015 12:03:00 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00922-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/1/2015 12:03:00 PM CHRISTOPHER PRINE CLERK No. 14-14-00922-CV ____________________________ IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEXAS Kimberly R. Redo Appellant , v.

Katherine Moore Appellee. On Appeal from County Court at Law No. One (1) Of Harris County, Texas Trial Court Cause No. 1029105 UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT T O T HE H ONORABLE J USTICES OF T HIS C OURT :

Kimberly R. Redo, Appellant, file this Unopposed Motion for Extension of Time to File

Brief of Appellant and would show the Court as follows:

1. Appellant’s brief is due on Monday, June 1, 2015.

2. Appellant respectfully requests an extension of time for 30 days to file her brief.

3. In addition to his regular office and client commitments and responsibilities,

counsel for Appellant has been required to prepare for and attend to various other matters

including:

(a) Attend trial in Cause No. 2013-22591, styled Capital Plastic & Bags, Inc. v. Frank

Zhang and Daxwell Group, LLC, f/k/a Daxwell Group, L.P., pending in the 295 th

Judicial District Court of Harris County, Texas.

(b) Prepare for and attend depositions in Cause No. 2012-11729, styled PMB Precision

Medical Billing v. Bay Area Podiatry Associates , pending in the 165 th Judicial

District Court of Harris County, Texas.

(c) Prepare for and attend non-party deposition in Cause No. 2014-50460, styled 6100

Clarkson L.P., et. al. v. Melvin Grant, et al. , pending in the 295 th District Court of

Harris County, Texas.

(d) Prepare for and attend pre-trial conference in Case No. 4:15-cv-859, styled Carmelita

Sagum v. Deutsche Bank National Trust Company , pending in the United States

District Court for the Southern District of Texas, Houston Division.

(e) Prepare for and attend oral argument in Cause No. 2009-65488 in Case No. 14-14-

00744-CV, styled Mega Builders, Inc., d/b/a Mega & Associates v. Paramount

Stores, Inc., and Community National Bank ; In Fourteenth Court of Appeals.

(f) Prepare for and travel overseas to the Netherlands and Belgium, having left on

Friday, May 15, 2015, and returning on Sunday, May 24, 2015.

In addition to the above, the undersigned counsel has the following upcoming deadlines:

(g) Prepare a response to Motion for Summary Judgment and attend Summary Judgment

hearing on June 5, 2015, in Cause No. 2014-16000; styled Heritage Park Terrace

Homeowners Association vs. Mohammad F. Akbar, pending in the 113 th Judicial

District of Harris County, Texas.

(h) Prepare for and attend TCEQ hearing in SOAH Docket No. 582-15-3698; TCEQ

Docket No. 2014-0908-PST-E, styled In the Matter of an Enforcement Action Against

Adnan Najm d/b/a Kathy’s Sunmart , RN101943140, on June 11, 2015.

(i) Prepare for and attend hearing on Harris County’s Motion for Summary Judgment on

June 12, 2015, in Cause No. 2011-52524, styled Harris County, Texas, Plaintiff, vs.

S.K. and Brothers, Inc., and Trey Melcher and Yvonne Evie Melcher, Trustees of the

Evie Melcher Non-Exempt Trust, Defendants, pending in the 215 th Judicial District

Court, of Harris County, Texas.

(j) Prepare Joint Pre-Trial Statement in Adversary Case No. 14-03320, styled Gulam

Gulamali v. Ngo Xuan Dinh and Nina Nhathuy Dinh, pending in the Southern District

of Texas, which is due June 19, 2015.

(k) Attend hearing on June 19, 2015, in Cause No. 14-DCV-214552, styled In the Matter

of the Marriage of Edward Ochuwa and Nwabugwu Ochuwa, pending in the 328 th

Family District Court of Fort Bend County, Texas.

4. One previous extension for time was granted to Appellant on April 13, 2015, with

regard to the filing of her brief.

5. This Motion is not sought for delay only, but in order that justice may be properly

served.

P RAYER Appellant Kimberly R. Redo, respectfully requests that this Court grant her request for an

extension of 30 days, until Wednesday, July 1, 2015, to file her brief. Appellant prays for any

other relief to which it is entitled.

Respectfully submitted, W ILLIAM F. H ARMEYER & A SSOCIATES /s/William F. Harmeyer William F. Harmeyer State Bar No. 09019000 475 Arena Tower One 7322 Southwest Freeway Houston, Texas 77074 Tel: (713) 270-5552 Fax: (713) 270-7128 Email: wharmeyer@harmeyerlaw.com Attorney for the Appellant, Kimberly R. Redo .

CERTIFICATE OF CONFERENCE I hereby certify that I have contacted Mr. Steven Messer, attorney for Appellee,

Katherine Moore, as to the merits of the forgoing motion, and that he is unopposed to this

Motion for Extension of Time to File Appellant’s Brief.

/s/William F. Harmeyer William F. Harmeyer CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the

following parties or counsel of record on this 1 st day of June, 2015, in accordance with Rule 9.5

of the Texas Rules of Appellate Procedure.

Mr. Steven Messer

Haynes and Boone, LLP

1221 McKinney, Suite 2100

Houston, Texas 77010-2007

Attorney for Appellee,

Katherine Moore

Via Fax: (713) 236-5507

/s/William F. Harmeyer William F. Harmeyer