NO. 01-14-00990-CV

IN THE FIRST COURT OF APPEALS

____________________________________________________

MANFRED FINK, Appellant 

V.

JOANN D. ANDERSON, ET. AL., Appellees

_________________________________________________

On Appeal from the 152nd Judicial District Court, Houston Texas

Cause No. 2014-22740

__________________________________________________

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO 

FILE OPENING BRIEF

TO THE HONORABLE JUSTICES:

Comes now, Manfred Fink, and files this Unopposed Motion for Extension of 

Time to File Opening Brief, and in support thereof would respectfully show the 

Court as follows:

On or about January 28, 2015, the Court notified the parties that the clerk’s 

record had been filed on January 27, 2015. Under the Texas Rules of Appellate 

Procedure, appellant’s opening brief is due 20 days after that date, Monday, 

February 16, 2015. Because that date falls on a holiday observed by the Court, the 

brief would then be due on Tuesday, February 17, 2015. 

Page 1 of 4 

ACCEPTED

01-14-00990-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

2/17/2015 2:11:06 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 2/17/2015 2:11:06 PM CHRISTOPHER A. PRINE Clerk
Undersigned counsel now seeks a 2-week extension of time to file the 

appellant’s opening brief, extending the deadline for filing to March 3, 2015. No 

previous extensions of the briefing schedule have been requested by any party in this 

case. Appellees’ counsel has stated to Appellant’s counsel that they are not opposed 

to this motion. 

Undersigned counsel seeks additional time to prepare the brief in this case due 

to a recent family emergency, which has required her to be out of the office for a 

significant period since the Court issued its order. Allowing this extension will 

permit counsel the additional time needed to prepare the brief. 

 Undersigned counsel respectfully requests that this Court grant Appellant’s 

Unopposed Motion for Extension of Time to File Appellant’s Opening Brief. 

Respectfully submitted,

KEN PAXTON

Attorney General of Texas

CHARLES E. ROY

First Assistant Attorney General

JAMES E. DAVIS 

Deputy Attorney General for Civil Litigation

ROBERT O’KEEFE

Division Chief

Financial Litigation, Tax, and Charitable Trusts Division 

/s/ H. Melissa Mather____________________________

H. Melissa Mather

Page 2 of 4
State Bar No. 240102216

Assistant Attorney General

Financial Litigation, Tax, and Charitable Trusts Division

P.O. Box 12548

Austin, TX 78711-2548

(512) 475-2540 - Telephone

(512) 477-2348 – Fax

CERTIFICATE OF CONFERENCE

Undersigned counsel certifies that she spoke with and emailed with opposing 

counsel on February 12, 2015, and opposing counsel stated that they are not opposed 

to this motion. 

/s/ H. Melissa Mather________

H. Melissa Mather

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Appellant’s 

Unopposed Motion for Extension of Time to File Opening Brief was served on 

February 13, 2015, to the following counsel of record, by e-service and/or fax:

Wade T. Howard

Michael P. Cash

Alma F. Gomez

LISKOW & LEWIS

1001 Fannin St., Ste. 1800

Houston, TX 77002

wthoward@liskow.com

mpcash@liskow.com

afgomez@liskow.com

Andrew R. Harvin

Peter Wells

DOYLE, RESTREPO, HARVIN & ROBBINS

The Lyric Centre

449 Louisiana, Ste. 2300

Houston, TX 77002

aharvin@drhrlaw.com

pwells@drhrlaw.com

Page 3 of 4
Tim McDaniel

MCDANIEL HOHLT, PC

Two Greenway Plaza, Ste. 1030

Houston, TX 77046

tmcdaniel@mcdanielfirm.com

William B. Mateja

FISH & RICHARDSON, PC

1717 Main St., Ste. 5000

Dallas, TX 75201

mateja@fr.com

Arnold Anderson Vickery

Fred H. Sheperd

THE VICKERY LAW FIRM

Park Laureate Bldg.

10000 Memorial Dr., Ste. 750

Houston, TX 77024

andy@justiceseekers.com

fred@justiceseekers.com

Paul D. Flack

PRATT & FLACK, LLP

1331 Lamar St.

Four Houston Center, Ste. 1250

Houston, TX

pflack@prattflack.com

/s/ H. Melissa Mather_______________

H. Melissa Mather

Page 4 of 4