NO. 14-14-00922-CV

IN THE COURT OF APPEALS

FOR THE FOURTEENTH DISTRICT OF TEXAS

AT HOUSTON

KIMBERLY R. REDO,

Appellant,

v.

KATHERINE MOORE,

Appellee.

APPELLEE’S THIRD UNOPPOSED MOTION 

TO EXTEND TIME TO FILE BRIEF AND FIRST UNOPPOSED MOTION 

TO RESET ORAL ARGUMENT

TO THE HONORABLE COURT OF APPEALS:

Appellee, Katherine Moore files this motion under Texas Rules of Appellate 

Procedure 10.5(b) and 10.5(c) and respectfully requests: (1) a 30-day extension of 

time, until October 30, 2015, to file her appellee’s brief, and (2) that oral argument 

be postponed for at least 30 days. 

ACCEPTED

14-14-00922-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

9/22/2015 4:57:46 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 9/22/2015 4:57:46 PM CHRISTOPHER A. PRINE Clerk
I.

This is an appeal from a Final Judgment signed on September 22, 2014, by 

the Honorable Debra Ibarra Mayfield, in the County Court at Law Number 1 of 

Harris County, Texas in cause number 1029105. Appellant filed a notice of appeal

on November 13, 2014. A complete record was filed on March 18, 2015. 

Appellant filed her brief on July 1, 2015.

II.

Appellee’s brief is currently due on September 30, 2015. Poorav Rohatgi, 

who is about to complete his first year as a practicing attorney, recently substituted 

as Counsel for Appellee on September 3, 2015 and has not had an opportunity to 

review the record thoroughly or evaluate applicable arguments and case law 

sufficiently. Further, recently substituted Counsel for Appellee has been 

substantially involved in the following matters, among others, throughout the 

month of September necessitating the filing of this motion:

1. Alta Mesa v. ReOil, et al.; Counsel prepared and filed a Motion for

Continuance on September 3, 2015.

2. Quintanilla v. Regency, et al.; Counsel drafted and served objections 

to a Third-Party Subpoena Duces Tecum on September 4, 2015. 

Counsel also drafted and filed a Non-Party Motion to Quash a Notice 

to Appear on September 15, 2015.

3. Roger Christ v. Habitat for Humanity, et al.; Counsel prepared for and 

aided a colleague during the September 14, 2015 deposition of the 

plaintiff.

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4. Academy, Ltd. v. Wipro, et al.; Counsel drafted objections to 

substantive interrogatories in anticipation of September 25, 2015 

deadline. Counsel also has been reviewing responsive documents and 

supervising a third-party’s substantial review of tens of thousands of 

documents for production in discovery in anticipation of October 9, 

2015 deadline.

Counsel also has volunteered as a City of Houston Municipal Prosecutor one 

to two days a week for the entire month of September.

Accordingly, Appellee respectfully requests a 30-day extension, or until 

October 30, 2015, in which to file her brief. This is Appellee’s third request for an 

extension of time. This motion is not filed for the purpose of delay. 

III.

The Court has set oral argument in this appeal for Tuesday, October 27, 

2015 at 1:30 pm. However, for the reasons explained above, more time is needed 

to complete the briefing in this case. Appellee’s substituted counsel has been 

involved in this case for less than one month and has not yet had an opportunity to 

finish reading the record and draft the Appellee’s brief. 

Accordingly, Appellee respectfully requests that the Court postpone oral 

argument for at least 30 days. This is Appellee’s first request to reset oral

argument. This motion is not filed for the purpose of delay.

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PRAYER

For these reasons, appellee Katherine Moore respectfully requests that the 

Court grant these requests, extend the time for filing her brief to October 30, 2015, 

and postpone oral argument for at least 30 days.

Respectfully submitted,

HAYNES AND BOONE, LLP

/s/ Poorav Rohatgi

Poorav K. Rohatgi

State Bar No. 24093063

1221 McKinney, Suite 2100

Houston, Texas 77010-2007

Telephone: (713) 547-2000

Telecopier: (713) 547-2600

Poorav.Rohatgi@haynesboone.com

ATTORNEY FOR APPELLEE

KATHERINE MOORE

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CERTIFICATE OF CONFERENCE

In accordance with Rule 10.1(a)(5) of the Texas Rules of Appellate 

Procedure, I certify that I conferred with Mr. William F. Harmeyer, counsel for 

Appellant, who stated that he is unopposed to the relief requested.

/s/ Poorav Rohatgi

Poorav K. Rohatgi

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CERTIFICATE OF SERVICE

In accordance with the Texas Rules of Appellate Procedure, I certify that a 

true and correct copy of the Appellee’s Third Unopposed Motion to Extend Time to 

File Brief and First Request to Reset Oral Argument has been served on the 

following counsel of record via e-service on this 22nd day of September, 2015:

Counsel for Kimberly R. Redo:

William F. Harmeyer

WILLIAM F. HARMEYER & ASSOCIATES, P.C.

Suite 475 Arena Tower One

7322 Southwest Freeway

Houston, Texas 77074

/s/ Poorav Rohatgi

Poorav K. Rohatgi

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