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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 Loy A, 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 190 th Judicial District Court, Harris County, Texas

Trial Court Cause No. 2012-33464 IAN TAYLOR, JACOBUS STERKEN, STICHTING TINSEL GROUP, VITOL

HOLDING II S.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

CLERKmotion to extend time.
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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 coun s el 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, 136 th Judicial District of Texas (pretrial motions) • Tomsic v. Real Flame Co., Inc., Eastern District of Texas (responses to motions to dismiss) • Bortz v. The Tu thill Corporation, d / b / a Blue Mountain Ski Area, Carbon County , Pennsylvania (pre-trial motions) deadlines prior to the August 14 th deadline: 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 Appellan t 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's3

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, LETICIA LOYA, 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 Job4 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