Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/18/2015 11:21:28 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00260-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 11/18/2015 11:21:28 AM 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’ MOTION FOR
EXTENSION OF TIME TO FILE BRIEF L AW O FFICE OF G REGORY N. J ONES By: /s/ Gregory N. Jones SBN 10889450 2323 S. Shepherd, 14 th Fl. Houston, Texas 77019 (713) 979-4691 (713) 979-4440 – fax Counsel for Appellees *2
As pointed out in Appellee’s last request for extension, Appellees’ counsel
has health issues having incurred several seizures. As a result of various
prescribed medications, counsel has been unable to completely
function, including driving until mid-December 2015. When
coupled with the Thanksgiving and Christmas holiday seasons ,
Appellees therefore respectfully request an extension of sixty (60) days to file
their response brief in this appeal.
BACKGROUND FACTS 1. On March 19, 2015, the DeYoungs filed their notice of appeal. The
clerkʼs record was filed on June 16, 2015, the Appellants’ brief was filed on August
17, 2015, which means that Appellees’ brief was due September 17, 2105. This
date was extended to November 19, 2015, as a result of Appellees’ previous
unopposed request for extension.
2. Appellees’ counsel’s health condition has prevented Appellees’
counsel from devoting the necessary time and attention to their response brief.
PRAYER / RELIEF REQUESTED
For the foregoing reasons, Appellees request an extension of at least 30-
day the deadline to file their brief, or until January19, 2016.
Respectfully submitted, L AW O FFICE OF G REGORY N. J ONES /s/ Gregory N. Jones 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’ counsel who
indicated that appellees are opposed to the relief sought by this motion.
/s/ Gregory N. Jones Gregory N. Jones *4 CERTIFICATE OF COMPLIANCE
Pursuant to TEX. R. APP. P. 9.4(i), I certify to the Court that the
foregoing document contains 441 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 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 November 18th, 2015:
/s/ Gregory N. Jones Gregory N. Jones Daniel W. Jackson, SBN 00796817 William L. Maynard
Scott K. Vastine, SBN 24056469 1300 Post Oak Blvd. Ste. 2500
3900 Essex Lane, Suite 1116 Houston, Texas 77056
Houston, Texas 77027 Fax: (713) 960-1527
(713) 527-8850 – fax
daniel@jacksonlaw-tx.com
scott@jacksonlaw-tx.com