Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/23/2015 2:30:50 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00396-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 11/23/2015 2:30:50 PM CHRISTOPHER PRINE CLERK CASE NO. 01-15-00396-CV IN THE FIRST COURT OF APPEALS HOUSTON, TEXAS _______________________________________ John W. Hankins v.
Sarah T. Harris _______________________________________ On Appeal from the 333rd Judicial District Court
of Harris County, Texas Trial Court Case No. 2014–01360 _______________________________________ A PPELLANT ’ S F IRST U NOPPOSED M OTION FOR E XTENSION OF T IME TO F ILE R EPLY B RIEF
TO THE HONORABLE COURT OF APPEALS:
Appellant, John W. Hankins requests a 7–day extension to file his
reply brief and for good cause, would show as follows:
1. Hankins’ reply brief is due on November 23, 2015.
2. This is Hankins’ first motion for extension of time to file his reply
brief.
3. Hankins respectfully requests a 7–day extension to file his reply brief
so that the undersigned can adequately prepare the same.
4. The undersigned’s litigation docket during the last two weeks has
prevented him from completing Hankins’ reply brief in this case.
Specifically, the undersigned:
Prepared and filed a brief on the merits with the Supreme Court
of Texas on November 12, 2015, in the case–styled and numbered, Ex parte Norman Crittenden , Case No. 15–0184. Prepared and filed a brief on the merits with the Supreme Court
of Texas on November 12, 2015, in the case–styled and numbered, McLean v. Livingston , Case No. 15–0100. Prepared and filed a reply brief on the merits with the Supreme
Court of Texas on November 12, 2015, in the case–styled and numbered, Steve Bumpas Custom Homes, Inc. v. Chris Wallace, et al , Case No. 15–0321.
Prepared and filed a motion for rehearing with the Supreme
Court of Texas on November 10, 2015, in the case–styled and numbered, Worldwide Clinical Trials v. Arnold , Case No. 14– 0786.
Prepared and prosecuted a jury trial on November 18, 2015.
Prepared and presented a CLE seminar in El Paso on November
19, 2015.
5. Also, the undersigned’s grandmother passed away last week. The
undersigned attended her funeral on November 20, 2015, which caused
him to be out of the office.
6. Also, the undersigned had various meetings, prepared motions and
briefs to be filed in other cases, prepared responses to motions, attended
hearings, and conducted activities usually associated with a litigation
practice in the last two weeks.
7. As such, the undersigned has not had sufficient time to prepare the
reply brief in this case.
8. Pursuant to T EX . R. A PP . P. 10.3, the undersigned conferred with
counsel for the Appellee, and counsel is unopposed to this motion.
FOR THESE REASONS, Appellant prays that this Honorable Court
grant this motion for extension of time and extend the deadline for filing
his reply brief to November 30, 2015, and requests all other relief to which
he may be entitled.
Respectfully submitted, LEYH, PAYNE & MALLIA, PLLC By: /s/ Sean M. Reagan Sean Michael Reagan sreagan@lpmfirm.com Texas Bar No. 24046689 9545 Katy Freeway, Suite 200 Houston, Texas 77024 Telephone: 713-785-0881 Facsimile: 713-784-0884 ATTORNEY FOR APPELLANT *4 CERTIFICATE OF SERVICE I certify that a true and correct copy of this document has been served
to all interested parties of record on November 23, 2015 as follows:
Brian B. Kilpatrick Via Email
H. Fred Cook Via Email
Wilson, Cribbs & Goren, P.C.
2500 Fannin Street
Houston, Texas 77002
Jarrett L. Ellzey Via Email
W. Craft Hughes Via Email
Hughes Ellzey, L.L.P.
2700 Post Oak Blvd., Suite 1120
Galleria Tower I
Houston, Texas 77056
Hartley Hampton Via Email
Hampton & King
3 Riverway, Suite 910
Houston, Texas 77056
William Feldman Via Email
Michael J. Mazzone Via Email
Michael T. Powell Via Email
Robert Carlton Via Email
Haynes & Boone, LLP
1221 McKinney Street, Suite 2100
Houston, Texas 77010-2007
/s/ Sean M. Reagan Sean M. Reagan