No. 14-14-00927-CV 

 

In The 

Fourteenth Court of Appeals at Houston, Texas 

 

ULRIKA BJORKSTAM AND JOSEPH DANIEL DRAY, 

Appellants, 

v. 

WOODWARD, INC., 

Appellee. 

On Appeal from the 190th Judicial District Court Of 

Harris County, Texas 

Trial Cause No. 2010-31214 

The Honorable Patricia J. Kerrigan, Presiding 

SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLANTS’ BRIEF 

Ulirka Bjorkstam and Joseph Daniel Dray file their Second Unopposed 

Motion for Extension of Time to File Appellants’ Brief, pursuant to Tex. R. App. 

P. 10.5(b). 

1. Presently, Appellants’ Brief is due March 2, 2015. 

2. Through this Unopposed Motion, Appellants seek an extension of 

twenty-one (21) days to file their Brief. Should the Court grant this Motion, the 

new deadline will be March 23, 2015. 

3. Contemporaneously with this Motion, Appellants filed their 

Unopposed Motion to Supplement the Reporter’s Record. Through that Motion, 

ACCEPTED

14-14-00927-cv

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

3/2/2015 3:19:43 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/2/2015 3:19:43 PM CHRISTOPHER A. PRINE Clerk
2 

Appellants seek to add the transcript of a hearing that occurred on May 17, 2013. 

There is a reference to the May 17th hearing in the Reporter’s Record currently on 

file with the Court. The May 17th hearing transcript is necessary for the complete 

presentation of Appellants’ arguments. The court reporter is ready to file the May 

17th hearing transcript, if the Court should grant Appellants’ Unopposed Motion to 

Supplement the Reporter’s Record. 

4. Additionally, Appellants’ counsel argued before the Delaware 

Supreme Court on February 18, 2015 in Bell Helicopter Textron, Inc. v. Andres 

Arteaga, et al., Case Number 333, 2014. As a result, the first eighteen days of 

February were devoted to preparing for this argument, as well as getting 

acclimated to a new law firm. Moreover, upon return from Delaware, where the 

weather was extremely cold, Appellants’ counsel fought cold and flu symptoms for 

several days. 

5. Counsel for Woodward, Inc., has no objection to the requested 

extension of twenty-one (21) days. Therefore, should the Court grant this Motion, 

the extension will not result in undue hardship or material harm to Woodward, Inc. 

6. Appellants have previously sought a thirty-day extension from the 

Court. 

For these reasons, Appellants request that the Court grant their Second 

Unopposed Motion for Extension of Time to File Appellants’ Brief. 
3 

Respectfully submitted, 

PIERCE & O’NEILL, LLP 

/s/ John C. Schwambach, Jr. 

John C. Schwambach, Jr. 

Texas State Bar Number 17858450 

4203 Montrose Boulevard 

Houston, Texas 77006 

713-634-3607 Direct 

713-634-3600 Main 

713-634-3601 Facsimile 

jschwambach@pierceoneill.com

 Attorney for Appellants 
4 

CERTIFICATE OF CONFERENCE 

I, John C. Schwambach, Jr., counsel for Appellants, Ulrika Bjorkstam and 

Joseph Daniel Dray, hereby certify that I have conferred with Timothy S. McConn, 

counsel for Appellee, about the merits of this Motion, and he is unopposed to this 

Motion. 

 /s/ John C. Schwambach, Jr. 

John C. Schwambach, Jr. 

 
5 

CERTIFICATE OF SERVICE 

 Pursuant to the Texas Rules of Appellate Procedure, I hereby certify that a 

true and correct copy of the foregoing was electronically filed and served upon all 

know counsel of record this 2nd day of March, 2015. 

 

/s/ John C. Schwambach, Jr. 

John C. Schwambach, Jr.