Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/8/2015 5:48:42 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00326-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 9/8/2015 5:48:42 PM CHRISTOPHER PRINE CLERK No. 01-15-00326-CV IN THE COURT OF APPEALS FIRST DISTRICT OF TEXAS HOUSTON, TEXAS DON ABBOTT HOLMES, GAYLE EISLER HOLMES, and the COMMUNITY PROPERTY
ESTATE OF DON ABBOTT HOLMES and GALE EISLER HOLMES, V.
JETALL COMPANIES, INC. On Appeal from the 127 th Judicial District Court Harris County, Texas APPELLEE’S MOTION TO EXTEND TIME Lee Keller King 2500 West Loop South Suite 255 (713) 789-7654 (713) 789-3331 fax Lee.k@jetallcompanies.com Attorney for Appellee *2 APPELLEE’S MOTION TO EXTEND TIME
Appellee, Jetall Companies, Inc., asks the Court to extend the time to file its Appellee’s
Brief, and would show as follows.
A. Introduction 1. Appellants are Don Abbott Holmes, Gayle Eisler Holmes, and The Community
Property Estate Of Don Abbott Holmes and Gale Eisler Holmes. Appellee is Jetall Companies,
Inc.
2. This motion is filed before the deadline for Appellee to file its Appellee’s Brief.
3. Counsel for Appellants has agreed to the granting of the relief sought in this motion.
B. Argument & Authorities 4. The Court may grant an extension of time under the authority of Rule 38.6(d) of
the Texas Rules of Appellate Procedure.
5. The deadline to file Appellee’s Brief is September 9, 2015 and this motion is filed
prior to that date.
6. Appellee requests an additional 30 days to file its Appellee’s Brief, extending the
time until Friday, October 9, 2015.
7. No extension has been granted to extend the time to file Appellee’s Brief.
8. The Court has previously been granted a 30-day extension to file their Appellants’
Brief.
9. Appellee needs additional time to file Appellee’s Brief because of difficulties in
obtaining appellate counsel.
C. Conclusion 10. Appellee has shown that Appellants are agreed to the granting of this motion, the
Court has the authority to grant Appellee an extension, that no previous extension has been granted
and there is good cause to grant the requested extension.
D. Prayer 11. For these reasons, Appellee asks the Court to grant an extension of time to file
Appellee’s Brief until Friday, October 9, 2015.
/s/Lee Keller King 2500 West Loop South Suite 255 (713) 789-7654 (713) 789-3331 fax Lee.k@jetallcompanies.com Attorney for Appellee CERTIFICATE OF CONFERENCE I certify that I conferred with Mr. Martin J. Siegel, counsel for Appellants, by telephone on
September 8, 2015, and he has agreed and is unopposed to the forgoing Appellee’s Motion to
Extend Time.
/s/ Lee Keller King *4 CERTIFICATE OF SERVICE I hereby certify that I served a copy of the forgoing motion on all counsel of record, as
listed below, via electronic service on September 8, 2015.
/s/ Lee Keller King Martin J. Siegel
Texas State Bar No. 18342125
L AW O FFICES O F M ARTIN J. S IEGEL , P.C.
Bank of America Center
700 Louisiana Street, Suite 2300
Houston, TX 77002
Tel.: (713) 226-8566
Martin@siegelfirm.com
Geoffrey Berg
B ERG F ELDMAN J OHNSON
B ELL , LLP
4203 Montrose Blvd., Suite 150
Tel.: (713) 526-0200
Gberg@bfjblaw.com