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No. 14-14-00459-CV

A.P.,

Appellant

v. 

N.H., 

Appellee

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Court of Appeals of Texas

Fourteenth District

Appellee’s Unopposed Motion for Extension of Time

to File Appellee’s Brief

Appellee N.H. files this Unopposed Motion for Extension of Time to file 

Appellee’s Brief and would respectfully show this Court the following:

1. Appellee’s Brief is due April 15, 2015.

2. Appellee respectfully requests an 8-day extension of her deadline. If 

permitted, his brief would be due on April 23, 2015.

3. Appellee seeks this extension because, during the previous thirty days

and through tomorrow, her counsel has been obligated with the following

additional deadlines:

— March 23, 2015: Response to Motion to Dismiss in Wesson v. City of 

Dallas, which is pending in the United States District Court for the 

Northern District of Texas as Civil Action No. 3:14-CV-4325;

— March 24, 2015: Response to three motions for summary judgment in 

Melendez v. Rumsey Site Construction, LLC, which is pending in the 

ACCEPTED

14-14-00459-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

4/14/2015 5:19:25 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 4/14/2015 5:19:25 PM CHRISTOPHER A. PRINE Clerk
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62nd Judicial District Court of Hopkins County, Texas as Cause No. 

CV-41232; 

— March 30, 2015: Response to motion for summary judgment in Blair v. 

City of Dallas, which is pending in the United States District Court 

for the Northern District of Texas as Civil Action No. 3:14-CV-1515;

— March 31, 2015: Hearing on three motions for summary judgment in 

Melendez v. Rumsey Site Construction, LLC, which is pending in the 

62nd Judicial District Court of Hopkins County, Texas as Cause No. 

CV-41232; 

— April 6, 2015: Response to Motion to Dismiss in Harper v. City of 

Dallas, which is pending in the United States District Court for the 

Northern District of Texas as Civil Action No. 3:14-CV-2647; and

— April 7, 2015: Response to Motion to Dismiss in Tolan v. City of 

Bellaire, which is pending in the United States District Court for the 

Southern District of Texas as Civil Action No. 4:09-CV-1324;

— April 9, 2015: Full-day mediation in Melendez v. Rumsey Site 

Construction, LLC, which is pending in the 62nd Judicial District 

Court of Hopkins County, Texas as Cause No. CV-41232;

— April 13, 2015: Appellant’s Brief due in Gonzalez v. Northfork 

Investments, Ltd., which is pending in the Fifth Court of Appeals as 

Case No. 05-14-01418-CV;

— April 15, 2015: CLE presentation in Lubbock, Texas; and

— April 16, 2015: CLE presentation in San Antonio, Texas

4. Appellee has requested and received one previous thirty-day extension

of time to file her brief in this case.

5. This motion is not made for purposes of delay, but so that justice may 

be done.
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Respectfully submitted,

s/ Matthew J. Kita

Matthew J. Kita

Texas Bar No. 24050883

1400 Congress Street

Houston, Texas 77002

(713) 222-2000 (telephone)

(713) 222-2329 (facsimile)

matt@mattkita.com

Counsel for Appellee

Certificate of Conference

On April 14, 2015, I conferred with Appellant’s counsel regarding the merits 

of this motion, who represented that he is unopposed to the relief requested. 

/s/ Matthew J. Kita

Matthew J. Kita

Certificate of Service

The undersigned certifies that a copy of this filing was served on the 

following counsel via e-filing in accordance with Texas Rule of Appellate Procedure 

9.5 and this Court’s Local Rules on April 14, 2015:

Counsel for Appellant:

Tej Paranjpe 

Paranjpe & Mahadass LLP 

3701 Kirby Drive, Suite 530 

Houston, TX 77098

s/ Matthew J. Kita

Matthew J. Kita