01-15-00597-CV

IN THE COURT OF APPEALS

FOR THE FIRST COURT OF APPEALS DISTRICT

HOUSTON, TEXAS

LEVENT ULUSAL,

Appellant,

V.

LENTZ ENGINEERING, L C

Appellee.

MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

Daniel Kistler

Daniel Kistler, Attorney at Law

Office Address:

17041 El Camino Real

Ste. 204

Houston, Texas 77058

Mailing Address:

2617C West Holcombe

No. 421

Houston, Texas 77025

Telephone: (713) 855-0827

Facsimile: (866) 352-5124

kistlerattorney@comcast.net

ATTORNEY FOR APPELLANT

ACCEPTED

01-15-00597-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

12/2/2015 11:25:43 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 11:25:43 PM CHRISTOPHER A. PRINE Clerk
1

MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

Comes now, Ulusal Levent, Appellant herein, and files this his first 

Motion for Extension of Time to File Reply Brief, and in support would 

show the following:

1. Appellee Lentz Construction, L.C. filed its Brief on November 

12, 2015. Pursuant to Rule 38.6(c), Tex. R. App. P., the deadline for filing 

Appellant’s Reply Brief is December 2, 2015.

2. Appellant seeks an additional fourteen (14) days, or until 

December 16, 2015, in which to file its Reply Brief.

3. Appellant’s counsel has been delayed in the preparation and 

finalization of this brief due to trial commitments in Cause No. 2014-43377; 

Christopher Stanzel, et al, v. John Hinkle, pending in the 190th Judicial 

District Court of Harris County, Texas, which is presently set for trial on 

December 7, 2015; Cause No. 2014-15521; Harris County, et al v. L V 

Thompson, 55th Judicial District Court of Harris County, Texas, which is 

presently set for trial on December 9, 2015, and Cause No. 2014-39578; 

Harris County, et al v. Ramona Jones, et al; which was set for trial on 

December 1, 2015, and not continued from that setting until the trial date. 

4. Appellant’s counsel believed that he would be able to complete 

this Reply Brief, despite the time required for trial preparations in the cases 
2

cited above, other matters which required his attention during the last 20 

days, and the Thanksgiving Holiday. However, it has become apparent that 

Appellant will require additional time in which to complete his Brief. 

Appellant reasonably requires an additional fourteen (14) days in which to 

complete and file his Brief.

5. This is the first motion for an extension of time to file 

Appellant’s Reply Brief.

CERTIFICATE OF CONFERENCE

6. Due to the late hour in filing this Motion, Appellant’ counsel is 

not able to contact counsel for the Appellee, Lentz Engineering, L.C. 

Appellant’s counsel shall apprise the court as soon as possible on whether 

Appellee has any objection to the relief requested.

Wherefore, premises considered, Appellant Levant Ulusal hereby 

requests that the court grant a fourteen (14) day extension of time for 

Appellant to file his Reply Brief, and for all other and further relief, at law 

and in equity, to which Appellant may be justly entitled.

Respectfully submitted,

/s/Daniel Kistler

Daniel Kistler, Attorney at Law

Office Address:

17041 El Camino Real

Ste. 204
3

Houston, Texas 77058

Mailing Address:

2617C West Holcombe

No. 421

Houston, Texas 77025

Telephone: (713) 855-0827

Facsimile: (866) 352-5124

kistlerattorney@comcast.net

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

On this 2nd day of December, 2015, a true and correct copy of 

the foregoing Motion for Extension of Time to File Reply Brief of 

Appellant Levant Ulusal was served on all counsel of record and 

pro se parties by certified mail, return receipt requested, facsimile 

transmission, electronic transmission and/or hand delivery.

Timothy R. Ploch via facsimile: (713) 862-7575 and

Linda M. Talbot email: lawplochstaff@flash.net

Timothy R. Ploch, P.C.

730 N. Post Oak Rd., Ste 100

Houston, Texas 77024

Keith Livesay

Livesay Law Office

Brazos Suites No. 9

McAllen, TX. 78504

Via email to: RGVAppellateLaw@yandex.com

/s/ Daniel Kistler