CASE NO. 01-17-00955-CV

IN THE FOURTEENTH COURT OF APPEALS AT HOUSTON, TEXAS

L

AURIE M EJIA -R OSA Appellant

vs.

JOHN MOORE SERVICES, INC, MBS FOUNTAINS OF TOMBALL LTD.

D/B/A FOUNTAINS OF TOMBALL, AND HENRY S. MILLER REALTY MANAGEMENT, LLC Appellee

On Appeal from 215th District Court Harris County, Texas Trial Court Cause No . 2014-00998 and 2014-00998A

FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S OPENING BRIEF

Caj D. Boatright State Bar No. 24036237 cboatright@arnolditkin.com Kurt Arnold State Bar No. 24036150 karnold@arnolditkin.com Alison Baimbridge State Bar No. 24040160 abaimbridge@arnolditkin.com ARNOLD & ITKIN LLP 6009 Memorial Drive Houston, TX 77007 Telephone: (713) 222-3800 Facsimile: (713) 222-3850 e-service@arnolditkin.com C OUNSEL FOR A PPELLANT ACCEPTED 01-17-00955-CV FIRST COURT OF APPEALS

HOUSTON, TEXAS 3/20/2018 1:47 PM CHRISTOPHER PRINE

CLERKT O THE H ONORABLE F IRST C OURT OF A PPEALS :

Appellant Laurie Mejia-R osa, through undersigne d counsel, respectfully

moves this honorable Court for an extension of time in which to file a Response to

the brief in the above-captioned appeal , and as grounds states as follows:

1. The present deadline for filing the brief is March 23, 2018.

2. Appellants seek a 60-day extension, until May 22, 2018, in which to

file their brief.

3. This is Appellants’ first request for an extension of time to file their

brief.

4. For the last few weeks, Counsel for Mejia-Rosa has been required to

travel out-of-state on numerous occasions for hearings and depositions.

Additionally, Counsel for Mejia-Rosa is preparing for a Jones Act trial that isi

preferentially set and will begin on Monda y, March 19, 2018, in Cause No. 2016-

14927; Jane Doe v. Transcoean Offshore Deepwater Drilling, Inc et al. in the 151st

District Court of Harris County, Texas.

5. Due to counsel for Mejia-Rosa’s current workload, previously

scheduled depositions, court appearances a nd trials in other matters, counsel for

Mejia-Rosa needs more time to adequately review the r ecord on appeal and prepare

Appellant’s brief.

6. Appellants’ brief is curre ntly due March 23, 2018.7. Appellants request an extension of 60 days, so that Appellants’ brief

may be prepared. Such an extension woul d extend the filing da te for Appellants’

reply brief to May 22, 2018.

8. This extension request is not inte nded for any undue delay or prejudice,

but so that Appellants have sufficient time to prepare their brief and that justice may

be done.

WHEREFORE, Appellants re spectfully request that this Honorable Court

grant this motion, affording them a 60-da y extension of time, through and until May

22, 2108, to file their opening brief

, and for such other and further relief as this

Honorable Court de ems appropriate.

Respectfully submitted,

ARNOLD & ITKIN LLP

/s/ Caj D. Boatright Caj D. Boatright State Bar No. 24036237 cboatright@arnolditkin.com Kurt Arnold State Bar No. 24036150 karnold@arnolditkin.com Alison Baimbridge State Bar No. 24040160 abaimbridge@arnolditkin.com ARNOLD & ITKIN LLP 6009 Memorial Drive Houston, TX 77007 Telephone: (713) 222-3800 Facsimile: (713) 222-3850 e-service@arnolditkin.com C OUNSEL FOR A PPELLANTCERTIFICATE OF CONFERENCE

Counsel for Appellants have conferre d with counsel for Appellee in a good faith effort to avoid any issues that might be raised by this motion. Counsel for Appellee has advised th at they have no opposition to th e extension of time requested herein.

/s/ Alison Baimbridge

Alison BaimbridgeCERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Unopposed

Motion for Extension of Time to File Appellant’s Reply Brief has been forwarded to

all counsel of record in ac cordance with the Texas Rule s of Appellate Procedure on

this 20 th day of March, 2018.

Mr. Michael W. Magee M EHAFFY W EBER 500 Dallas Street, Ste 1200 Houston, Texas 77002 michaelmagee@mehaffyweber.com patriciachamblin@mehaffyweber.com ATTORNEY FOR JOHN MOORE SERVICES, INC.

Spencer Edwards The Hudgins Law Firm 24 Greenway Plaza, Suite 2000 Houston, Texas 77046 Sedwards@hudgins-law.com ATTORNEY FOR TT-FOUNTAINS OF TOMBALL, LTD., INCORRECTLY NAMED AS MBS FOUNTAINS OF TOMBALL, LTD. D/B/A FOUNTAINS OF TOMBALL, AND HENRY S. MILLER REALTY MANAGEMENT, LLC

/s/ Alison Baimbridge

Alison Baimbridge