CASE NO. 01-17-00955-CV

IN THE FOURTEENTH COURT OF APPEALS 

AT HOUSTON, TEXAS

LAURIE MEJIA-ROSA

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

COUNSEL FOR APPELLANT 

ACCEPTED

01-17-00955-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

3/20/2018 1:47 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 3/20/2018 1:47:03 PM CHRISTOPHER A. PRINE Clerk
TO THE HONORABLE FIRST COURT OF APPEALS: 

Appellant Laurie Mejia-Rosa, through undersigned 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 Monday, 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 and trials in other matters, counsel for 

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

Appellant’s brief. 

6. Appellants’ brief is currently due March 23, 2018. 
7. Appellants request an extension of 60 days, so that Appellants’ brief 

may be prepared. Such an extension would extend the filing date for Appellants’ 

reply brief to May 22, 2018. 

8. This extension request is not intended 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 respectfully request that this Honorable Court 

grant this motion, affording them a 60-day 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 deems 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

COUNSEL FOR APPELLANT 
CERTIFICATE OF CONFERENCE

 Counsel for Appellants have conferred 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 that they have no opposition to the extension of time requested 

herein. 

/s/ Alison Baimbridge

 

 Alison Baimbridge 

 
CERTIFICATE 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 accordance with the Texas Rules of Appellate Procedure on 

this 20th day of March, 2018.

Mr. Michael W. Magee 

MEHAFFY WEBER

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