The opinion
ACCEPTED
01-14-00990-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/17/2015 2:11:06 PM
CHRISTOPHER PRINE
CLERK
NO. 01-14-00990-CV
FILED IN
IN THE FIRST COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
____________________________________________________
2/17/2015 2:11:06 PM
MANFRED FINK, Appellant CHRISTOPHER A. PRINE
Clerk
V.
JOANN D. ANDERSON, ET. AL., Appellees
_________________________________________________
On Appeal from the 152nd Judicial District Court, Houston Texas
Cause No. 2014-22740
__________________________________________________
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
FILE OPENING BRIEF
TO THE HONORABLE JUSTICES:
Comes now, Manfred Fink, and files this Unopposed Motion for Extension of
Time to File Opening Brief, and in support thereof would respectfully show the
Court as follows:
On or about January 28, 2015, the Court notified the parties that the clerk’s
record had been filed on January 27, 2015. Under the Texas Rules of Appellate
Procedure, appellant’s opening brief is due 20 days after that date, Monday,
February 16, 2015. Because that date falls on a holiday observed by the Court, the
brief would then be due on Tuesday, February 17, 2015.
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Undersigned counsel now seeks a 2-week extension of time to file the
appellant’s opening brief, extending the deadline for filing to March 3, 2015. No
previous extensions of the briefing schedule have been requested by any party in this
case. Appellees’ counsel has stated to Appellant’s counsel that they are not opposed
to this motion.
Undersigned counsel seeks additional time to prepare the brief in this case due
to a recent family emergency, which has required her to be out of the office for a
significant period since the Court issued its order. Allowing this extension will
permit counsel the additional time needed to prepare the brief.
Undersigned counsel respectfully requests that this Court grant Appellant’s
Unopposed Motion for Extension of Time to File Appellant’s Opening Brief.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
CHARLES E. ROY
First Assistant Attorney General
JAMES E. DAVIS
Deputy Attorney General for Civil Litigation
ROBERT O’KEEFE
Division Chief
Financial Litigation, Tax, and Charitable Trusts Division
/s/ H. Melissa Mather____________________________
H. Melissa Mather
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State Bar No. 240102216
Assistant Attorney General
Financial Litigation, Tax, and Charitable Trusts Division
P.O. Box 12548
Austin, TX 78711-2548
(512) 475-2540 - Telephone
(512) 477-2348 – Fax
CERTIFICATE OF CONFERENCE
Undersigned counsel certifies that she spoke with and emailed with opposing
counsel on February 12, 2015, and opposing counsel stated that they are not opposed
to this motion.
/s/ H. Melissa Mather________
H. Melissa Mather
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Appellant’s
Unopposed Motion for Extension of Time to File Opening Brief was served on
February 13, 2015, to the following counsel of record, by e-service and/or fax:
Wade T. Howard Andrew R. Harvin
Michael P. Cash Peter Wells
Alma F. Gomez DOYLE, RESTREPO, HARVIN & ROBBINS
LISKOW & LEWIS The Lyric Centre
1001 Fannin St., Ste. 1800 449 Louisiana, Ste. 2300
Houston, TX 77002 Houston, TX 77002
wthoward@liskow.com aharvin@drhrlaw.com
mpcash@liskow.com pwells@drhrlaw.com
afgomez@liskow.com
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Tim McDaniel William B. Mateja
MCDANIEL HOHLT, PC FISH & RICHARDSON, PC
Two Greenway Plaza, Ste. 1030 1717 Main St., Ste. 5000
Houston, TX 77046 Dallas, TX 75201
tmcdaniel@mcdanielfirm.com mateja@fr.com
Arnold Anderson Vickery Paul D. Flack
Fred H. Sheperd PRATT & FLACK, LLP
THE VICKERY LAW FIRM 1331 Lamar St.
Park Laureate Bldg. Four Houston Center, Ste. 1250
10000 Memorial Dr., Ste. 750 Houston, TX
Houston, TX 77024 pflack@prattflack.com
andy@justiceseekers.com
fred@justiceseekers.com
/s/ H. Melissa Mather_______________
H. Melissa Mather
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