*1
MOTION TO IMMEDIATELY FILE BRIEF OUT OF TIME
IN THE TWELFTH COURT OF APPEALS OF THE STATE OF TEXAS
MOTION TO IMMEDIATELY FILE BRIEF OUT OF TIME
- Background. The appellee's brief was due on December 20, 2016, and that day has passed. The appellee has asked for and received three prior extension of time to file brief.
- Authority. Pursuant to Rule 26(b)
- Reason. The appellee is a truck driver and the only family member now in a financial position to hire an attorney or find services that could aid him with this case. The appellee was not able to hire an attorney and was on the road working and the assistance and his niece whom are helping him, was not able to receive mail from the court of the date to file was December 20, 2016 not December 21, 2016.
Because of this, appellee ask for permission to file the brief immediately
Respectfully submitted
Grady L. Muhammad
a/k/a Grady L. Choice
4939 CR 4317
Larue, Texas 75770
*2 COURT OF APPEALS CASE NO.:12-16-00189 REQUEST FOR ORAL ARGUMENT
*3
CERTIFICATE OF SERVICE
Court of Appeal Case Number 12-16-00189 CV
The undersigned hereby certifies that on Friday, January 27, 2017, a copy of the foregoing response was served on the following counsel for Plains Pipeline, L.P. Counsel for Respondent received Certificate of Service for The Brief, Motion to Immediately File Brief and Request for Oral Arguments via fax to 210-249-3201.
Ross Molina Oliveros, P.C. 4118 Pond Hill Road, Ste#100 San Antonio, Texas 78231
(VERIFICATION REQUIRED IF SERVICE IS BY A PERSON OTHER THAN A PARTY OR PARTY'S ATTORNEY)
I declare under penalty of perjury that the information in this Certificate of Conference is true and correct.