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 152 nd 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 M otion 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

CLERKUndersigned coun sel 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 stat ed 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 Appell ant’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, Ta x, and Charitable Trusts Division

/s/ H. Melissa Mather

____________________________ H. Melissa Mather

Page 2 of 4State 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 1 2 , 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 t he following counsel of record, by e

- service and/or fax:

Wade T. Howard

Michael P. Cash

Alma F. Gomez

L ISKOW & L EWIS 1001 Fannin St., Ste. 1800 Houston, TX 77002

wthoward@liskow.com mpcash@liskow.com afgomez@liskow.com Andrew R. Harvin

Peter Wells

D OYLE

, R ESTREPO

, H ARVIN & R OBBINS The Lyric Centre 449 Louisiana, Ste. 2300 Houston, TX 77002

aharvin@drhrlaw.com pwells@drhrlaw.com

Page 3 of 4Tim McDaniel

M C D ANIEL H OHLT

, PC Two Greenway Plaza, Ste. 1030 Houston, TX 77046

tmcdaniel@mcdanielfirm.com William B. Mateja

F ISH & R ICHARDSON

, PC 1717 Main St., Ste. 5000 Dallas, TX 75201 mateja@fr.com

Arnold Anderson Vickery Fred H. Sheperd

T HE V ICKERY L AW F IRM Park Laureate Bldg. 10000 Memorial Dr., Ste. 750 Houston, TX 77024 andy@justiceseekers.com fred@justiceseekers.com Paul D. Flack

P RATT & F LACK

, 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