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02929.825 / 1733983.1 

01-14-00931-CV

IN THE COURT OF APPEALS 

FOR THE FIRST DISTRICT OF TEXAS 

HOUSTON, TEXAS 

COUNTRY TITLE, L.L.C. 

Appellant 

v. 

MORENIKE JAIYEOBA 

Appellee. 

APPELLANT’S FIRST MOTION TO EXTEND TIME 

TO FILE APPELLANT’S BRIEF 

TO THE HONORABLE COURT OF APPEALS, 

 Appellant, Country Title L.L.C. (“Country Title”) file this First Motion to 

Extend Time to File Appellant’s Brief pursuant to Texas Rule of Appellate 

Procedure 10 in support thereof would show the following circumstances warrant 

an extension: 

The reporter’s record in this case was filed on March 9, 2015 and the 

appellate record is not complete. Accordingly, Appellees’ deadline for filing its 

Appellant’s Brief is currently Wednesday, April 8, 2015. 

ACCEPTED

01-14-00931-cv

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/1/2015 12:26:32 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/1/2015 12:26:32 PM CHRISTOPHER A. PRINE Clerk
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02929.825 / 1733983.1

Appellant seeks a thirty (30) day extension of time in which to file its

Appellant’s Brief, such that its brief is due on Friday, May 8, 2015. 

This request for extension of time is not sought to cause delay or prejudice, 

but only so that justice may be done. Appellant’s counsel has had scheduling 

conflicts throughout the month of March with deadlines which interfere with the 

current deadline. Specifically, Jim McConn, lead counsel for Country Title, has 

the scheduling conflicts:

03/13/2015 Docket Call/Pre-Trial Conference

 Cause No. 14-01-01117-CV

Robert Ling v. Andrew Musgrove v. Grand Harbor 

Property Owners Association

284th Judicial District Court of Montgomery County, 

Texas

03/13/2015 Preliminary Hearing Conference

 AAA NO. 01-14-0001-8183

LAS Properties, et al v. Pinnacle Ridge GP, LLC, et al

 American Arbitration Association

03/16/2015 Non-Jury Trial

 Cause No. 14-01-01117-CV

Robert Ling v. Andrew Musgrove v. Grand Harbor 

Property Owner Association

284th Judicial District Court of Montgomery County, 

Texas

03/16/2015 Motions for Summary Judgment Hearing

 Cause No. 2014-10063

Azim Keramati, et al vs. Planned Community 

Management, Inc., Fall Creek Homeowners Association, 

Inc., Severn Trent Services, Inc. and The Johnson 

Development Corp.

281st Judicial District Court of Harris County, Texas
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02929.825 / 1733983.1

03/17/2015 Motion to Compel Discovery Responses/Motion for 

Protection

 Cause No. 14-0177

Springlake Property Owners’ Association, Inc. v. Gerald, 

Kirk and Amy Kirk

22nd Judicial District Court of Hays County, Texas

03/20/2015 Appellees’ Brief due

Cause No. 01-14-00216-CV

Victor Elgohary v. Lakes on North Eldridge Community 

Association, Inc. et al. 

Court of Appeals for the First Judicial District, Houston, 

TX

03/30/2015 Motion to Enforce Mediation Settlement Agreement

 Cause No. 2012-50554

Jean M. Robingston, Nelida Cerna and Maricela Garcia 

v. Dilston House Condominium Association and Genesis 

Management Company, Inc.

234th Judicial District Court of Harris County, Texas

03/30/2015 Motion for Protection

Cause No. 2014-71936

Taylor Morrison of Texas, Inc. v.

Stewart, Tamesha Stewart and Greater Emmanuel 

Apostolic Church v. Advantage Title of Ft. Bend, L.C. 

and Raymond C. Kerr in his Capacity as Arbitrator

152nd District Court of Harris County, Texas

These deadlines represent some of the conflicts presently on Appellant’s 

counsel’s calendar and do not include depositions, discovery, and other ongoing 

case and client obligations. 
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02929.825 / 1733983.1

PRAYER

WHEREFORE PREMISES CONSIDERED, Appellant respectfully requests

that this Honorable Court grant it an extension of thirty (30) days to file its

Appellant’s Brief so that its deadline will be Friday, May 8, 2015, and for any such 

further relief to which it may be entitled. 

 Respectfully submitted,

LeClairRyan

 

 /s/ James J. McConn, Jr. 

By:_________________________

James J. McConn, Jr.

Email: james.mcconn@leclairryan.com

1233 West Loop South, Suite 1000

Houston, Texas 77027

Telephone: 713-654-1111

Facsimile: 713-650-0027

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), (e), I certify 

that I have served this document on all other parties which are listed below on 

April 1, 2015 as follows:

Teltschik-Grubbs, PLLC

Corwin L. Teltschik

Betsy Grubbs

14015 Southwest Freeway, Suite 4

Sugar Land Texas 77478

Fax: 281-201-1202 /s/ James J. McConn, Jr. 

_________________________

James J. McConn, Jr.
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02929.825 / 1733983.1

CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I 

contacted Appellee’s counsel on March 30, 2015 by email. Appellee’s counsel

indicated they are unopposed to Appellant’s First Motion to Extend Time to File 

Appellant’s Brief.

/s/ James J. McConn, Jr. 

_________________________

James J. McConn, Jr.