NO. 14-14-00986-CV 

IN THE COURT OF APPEALS 

FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS 

HOUSTON, TEXAS 

THE PENN INSURANCE AND ANNUITY COMPANY 

AND THE PENN LIFE MUTUAL LIFE INSURANCE COMPANY 

APPELLANTS 

vs. 

CHAD KURIGER, APPELLEE 

On Appeal from the 151ST Judicial District Court 

of Harris County, Texas 

Cause No. 2013-59559 

APELLANTS, THE PENN INSURANCE AND ANNUITY COMPANY 

AND THE PENN MUTUAL LIFE INSURANCE COMPANY’S 

AGREED MOTION TO EXTEND TIME TO FILE APPELLANTS’ BRIEF 

Scott B. Novak 

SBN: 24051124 

 LORANCE & THOMPSON, P.C. 

 2900 North Loop West, Suite 500 

 Houston, Texas 77092 

 713/868-5560 

 713/864-4671 (fax) 

 Sbn@lorancethompson.com

 COUNSEL FOR APPELLANTS 

 THE PENN INSURANCE AND 

 ANNUITY COMPANY AND 

THE PENN MUTUAL LIFE 

INSURANCE COMPANY 

ACCEPTED

14-14-00986-cv

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

4/10/2015 10:48:18 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 4/10/2015 10:48:18 AM CHRISTOPHER A. PRINE Clerk
TO THE HONORABLE FOURTEENTH COURT OF APPEALS: 

COME NOW The Penn Insurance and Annuity Company and The Penn 

Mutual Life Insurance Company (hereinafter “Appellants”), and file this Agreed 

Motion to Extend Time to File Brief of Appellants and respectfully show unto the 

Court the following: 

 Appellants, The Penn Insurance and Annuity Company and The Penn 

Mutual Life Insurance Company, ask the Court to extend the time to file their Brief. 

I. 

 1. Reporter’s Record was filed on March 18, 2015 and the Clerk’s Record 

was filed on March 25, 2015. 

 2. Appellants’ Brief is presently due on Friday, April 24, 2015. 

 3. Due to an unexpectedly busy schedule, counsel for the Appellants does 

not believe it is feasible to dedicate the suitable amount of time to briefing this 

matter. To ensure adequate time is available, Appellants ask this Court to extend the 

due date for Appellants’ brief. 

 4. Appellants have conferred with counsel for Chad Kuriger and he is in 

agreement with the requested extension. 

 5. Appellants respectfully request an additional sixty (60) days from the 

April 24, 2015 due date to file his Brief. This would extend the time to file 

Appellants’ Brief to June 23, 2015. 
 6. This is Appellants’ first request for an extension to file their Brief. 

 7. For these reasons, Appellants respectfully request an additional sixty 

(60) days in which to file their Brief. 

 9. This request is not sought for delay. 

II. 

 For these reasons, Appellants ask this Court to grant an extension of time to 

file their Brief to June 23, 2015. 

Respectfully submitted, 

 LORANCE & THOMPSON, P.C. 

 /s/ Scott B. Novak 

 ______________________________ 

Scott B. Novak 

SBN: 24051124 

 2900 North Loop West, Suite 500 

 Houston, Texas 77092 

 713/868-5560 

 713/864-4671 (fax) 

 sbn@lorancethompson.com

COUNSEL FOR APPELLANTS 

 THE PENN INSURANCE AND 

 ANNUITY COMPANY AND 

THE PENN MUTUAL LIFE 

INSURANCE COMPANY 
CERTIFICATE OF CONFERENCE 

 I conferred with opposing counsel on April 9, 2015 regarding this motion 

and he is unopposed. 

 /s/ Scott B. Novak 

____________________________________ 

Scott B. Novak 

CERTIFICATE OF SERVICE 

I hereby certify that on this 10th day of April, 2015, a true and correct copy 

of the foregoing instrument was served by e-filing and/or facsimile, to the 

following party of record: 

Mr. David Ayers 

Werner Ayers, LLP 

1800 Bering, Suite 305 

Houston, Texas 77057 

dayers@wernerayers.com

Counsel for Plaintiff/Appellee 

 

 _____________________________ 

Scott B. Novak