1 No. 14

- 115

- 00 087- CV

In the Court of Appeals for the

Fourteenth District of Texas at Houston

HARPINDER SINGH, ET AL.

Appellant

V.

GURNAM SINGH SANDHAR ET AL.

Appellee

On Appeal from the 55 th Judicial District Court

Harris County, Texas

Trial Court Case No. 2013-51397

APPELLANT’S MOTION FOR AN EXTENSION OF TIME

TO FILE APPELLANT’S BRIEF ON THE MERITS

To the Honorable Fourteenth Court of Appeals:

1. Appellants’, Harpinder Singh, et al., respectfully f ile this

motion for a thirty (45 ) day extension of time to file the Clerk’s record and

in support respectfully state as follows: ACCEPTED

14-15-00087-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

7/2/2015 10:58:58 AM

CHRISTOPHER PRINE

CLERK2

2. The brief of Appellants is due on July 6, 2015. This is

Appellants’ first request for an extension of time to file their brief.

3. Appellants are requesting 45 days from the granting of this

Motion in which to file their Appellant’s Brief on the Merits.

4. The counsel for Appellant is unable to confer with all

Appellees, as they are individuals unrepresented by counsel, and the

undersigned does not have a telephone numb er for each Appellee.

5. Counsel for the Appellant seeks this extension of time because

the Reporter’s record was just filed on June 3, 2015. Since that time,

Appellant’s counsel, Kristen Coleman, has had multiple evidentiary hearings

which have required sig nificant time to prepare. Ms. Coleman also went on a

three day vacation. Ms. Coleman seeks additional time to prepare the

Appellant’s brief.

6. It is for these reasons that counsel for Appellant has been

unable to complete the Brief on the Merits and is re questing an extension of

time. The undersigned attorney understands the importance of deadlines and

is not requesting this extension for reasons of delay only, but that justice

may be done.3

WHEREFORE, PREMISES CONSIDERED, the Appellant

respectfully reque sts the Court to extend the time for filing her Brief on the

Merits in this cause by 30 days from the date of the Court’s granting of this

Motion

.

Respectfully submitted,

WOODFILL LAW FIRM, PC

/s/ Kristen Coleman

____________ Kristen Co leman

State Bar No.: 24038825

kcoleman@woodfilllaw.com

River Oaks Green

3131 Eastside St., Suite 450

Houston, Texas 77098

Telephone: 713

- 751

- 3080

Facsimile: 713

- 751

- 3058

Certificate of Conference

Pursuant to Tex. R. App. P. 10.1(5), this is to certify that I did not

confer with the individual Appellees, because they are not represented by

counsel.

/s/ Kristen S. Coleman

Kristen Coleman

Attorney for Appellant4 CERTIFI CATE OF SERVICE

I he reby certify that on this 2nd day of July , 2015, a true and correct

copy of the foregoing document has been served on counsel below:

Via USPS First Class Mail

Gurnam Singh Sandhar

7 Harbor Bend Drive

Houston, Texas 77070

Via USPS Fir

st Class Mail

Inqlabi Thandi

9910 Oxted

Spring , Texas 77 379

Via USPS First Class Mail

Daljit Singh Baganti

19027 Rustling Ridge Lane

Tomball, Texas 77377

Via USPS First Class Mail

Baljinder Singh Bhatti

14355 Cornerstone Village Dr. #911

Houston, Texas 7 7014

Via USPS First Class Mail

Sodagar Singh Virk

2413 Air Line Dr.

Brenham, Texas 77833

Via USPS First Class Mail

Baljinder Singh

12206 Winderwick

Houston, Texas 77066

Via Email

Briseida Luna

/s/ Kristen S. Coleman

Kristen Coleman