Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/17/2015 1:34:57 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00260-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 9/17/2015 1:34:57 PM CHRISTOPHER PRINE NO. 01-15-00260-CV CLERK IN THE COURT OF APPEALS FOR THE 1ST JUDICIAL DISTRICT OF TEXAS AT HOUSTON JOAN DEYOUNG, STEPHEN DEYOUNG, M.D, AND DAVID DEYOUNG,
Appellants, V.
Judy Page Maynard, William L. Maynard, Maynard Properties, L.P.,
Appellees. FROM THE 270TH JUDICIAL DISTRICT COURT OF HARRIS COUNTY, TEXAS APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF SBN 10889450 Law Office of Gregory N. Jones 2323 S. Shepherd, 14 th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax Counsel for Appellees *2
Appellees’ counsel has been involved in several litigation
matters out of the county and State litigation matters, Appellees
respectfully requests a thirty (30) day extension of the deadline to file their
response brief in this appeal.
BACKGROUND FACTS 1. On March 19, 2015, the DeYoungs filed their notice of appeal.
The clerk ʼ s record was filed on June 16, 2015, the Appellants’ brief was filed
on August 17, 2015, which means that Appellees’ brief is due September
17, 2105.
2. Appellees’ counsel is handling several complex cases that
have required an inordinate amount of time and attention over the past
several months.
3. These matters, and the resulting time constraints, have
prevented Appellees’ counsel from devoting the necessary time and
attention to their response brief.
4. This is the Appellees’ counsel first request for an extension
of time to file their response brief, which is unopposed.
PRAYER / RELIEF REQUESTED For the foregoing reasons, appellants Joan DeYoung, Stephen
DeYoung, M.D., and David DeYoung request a 30-day extension of the
deadline to file his brief, which would make the DeYoungs ʼ brief due on
August 17, 2015 (August 15th is a Saturday).
Respectfully submitted, Law Office OF G REGORY N. J ONES /s/ Gregory N. Jones 2323 S. Shepherd, 14 th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax gjones@gnjlaw.net Counsel for Appellees CERTIFICATE OF CONFERENCE I certify to the Court that I have conferred with appellees ʼ counsel who
indicated that appellees are unopposed to the relief sought by this motion.
/s/ Gregory N. Jones Gregory N. Jones
CERTIFICATE OF COMPLIANCE Pursuant to T EX . R. A PP . P. 9.4(i), I certify to the Court that the
foregoing document contains 371 words. In calculating the word count, I
relied on the “Word Count” function of the computer program used to
generate this document.
/s/ Gregory N. Jones CERTIFICATE OF SERVICE I certify that a copy of the foregoing document has been electronically
served on all counsel of record on September 17, 2015:
Daniel W. Jackson, SBN 007968 William L. Maynard
Scott K. Vastine, SBN 24056469 1300 Post Oak Blvd., Suite 2500
3900 Essex Lane, Suite 1116 Houston, Texas 77056
Houston, Texas 77027 (713) 623-0887
(713) 522-4435 (713) 960-1527 – fax
(713) 527- 8850 – fax
daniel@jacksonlaw-tx.com
scott@jacksonlaw-tx.com
/s/ Gregory N. Jones Gregory N. Jones