1

2015.

1. Appellant's Briefis due to be filed with this court on or about August 14,

time to file Appellant's Reply Brief, and respectfully states:

LETICIA LoyA, Appellant, moves this Court to grant an extension of

TO THE HONORABLE FIRST COURT OF APPEALS:

UNOPPOSED SECOND MOTION TO EXTEND

TIME FOR FILING APPELLANT'S REPLY BRIEF

Appeal from the 190th Judicial District Court, Harris County, Texas

Trial Court Cause No. 2012-33464

IAN TAYLOR, JACOBUS STERKEN, STICHTING TINSEL GROUP, VITOL

HOLDING IIS.A., ANDTINSEL GROUP, S.A.,

Appellees.

LETICIA LOYA,

Appellant,

IN THE COURT OF ApPEALS

FOR THE FmST DISTRICT OF TEXAS

AT HOUSTON

No.Ol-15-00197-CV

v.

ACCEPTED

01-15-00197-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

8/17/2015 12:00:00 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 8/17/2015 8:48:00 AM CHRISTOPHER A. PRINE Clerk
motion to extend time.

2

Tinsel Group, S.A., and Miguel Loya, and Appellees do not oppose this

Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A.,

4. Counsel for Appellant has conferred with counsel for Appellees Ian

this case.

Therefore, additional time is needed to adequately prepare the arguments in

delay, but rather to afford counsel adequate time to prepare the reply brief.

prepare the brief in this appeal. This request is not filed for the purpose of

• Universal Gold Coin v. FedEx et al, Western District of Tennessee

(pre-trial motions)

• Altamirano v. KONE, 136th Judicial District of Texas (pretrial

motions)

• Tomsic v. Real Flame Co., Inc., Eastern District of Texas (responses

to motions to dismiss)

• Bortz v. The Tuthill Corporation, d/b/a Blue Mountain Ski Area,

Carbon County, Pennsylvania (pre-trial motions)

deadlines prior to the August 14thdeadline:

was/is participating in several oral arguments, appeals and/or trials with

As a result, time constraints will make it difficult to adequately

counsel for trial in an unrelated matter. Also, lead counsel for Appellant

legal assistant inadvertently overlooked the deadline while assisting another

which would make Appellant's Brief due on or before August 17, 2015.

2. Appellant seeks a one (1) day extension of time to file Appellant's Brief,

3. This extension of time is necessary because lead counsel for Appellant's
3

I hereby certify that I conferred with counsel for Appellees Miguel

Loya, Ian Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II

S.A., and Tinsel Group, S.A. concerning this motion, and Appellees do not

oppose the relief requested in this motion.

CERTIFICATE OF CONFERENCE

By: / s / Jennifer Job

Jennifer Job

Texas State Bar No. 24050682

James Payne

Texas State Bar No. 00788171

ATTORNEYS FOR APPELLANT

PROVOST* UMPHREY LAW FIRM,

L.L.P.

490 Park Street

P. O. Box 4905

Beaumont, Texas 77704

(409) 835-6000

(409) 813-8682 (FAX)

Respectfully submitted,

she may be entitled.

including August 17,2015. Appellant also requests any other relief to which

render an order extending the time for filing Appellant's Brief to and

For these reasons, LETICIALOYA, Appellant, requests that this Court

the Appellant's Reply Brief.

5. This is the second extension of time Appellant has sought for the filing of

/ s/ Jennifer Job
4

Jennifer Job

I hereby certify that a copy of this motion to amend notice of appeal

has been sent to all known counsel of record via EFILE and/or certified

mail, return receipt requested on August 15, 2015.

CERTIFICATE OF SERVICE

/ s/ Jennifer Job