NO. 01-15-00463-CV

IN THE FIRST COURT OF APPEALS

AT HOUSTON

NURIA MANDJE,

 Appellant,

v.

CCI SERVICES, CORP.

 Appellee.

On Appeal from the 11 Judicial District Court of th

Harris County, Texas

APPELLANT’S UNOPPOSED MOTION 

TO EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE FIRST COURT OF APPEALS:

COMES NOW, Nuria Mandje, Appellant herein, and pursuant to TEX.R. APP.

P. 10 and 38.6(a), file this Unopposed Motion to Extend Time to File Appellant’s

Brief in the above captioned appeal, and in support thereof would show the

following:

1. The trial court, by order dated April 30, 2015, denied Appellant’s Special

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ACCEPTED

01-15-00463-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

5/22/2015 4:00:54 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 5/22/2015 4:00:54 PM CHRISTOPHER A. PRINE Clerk
Appearance in Cause No. 2014-59752; CCI Services, Corp. V. Nuria Mandje f/k/a

Nuria M. Caracciolo; In the 11 Judicial District Court, Harris County, Texas.

th

2. Appellant timely perfected an interlocutory appeal ofsaid order pursuant

to TEX.CIV. PRAC.& REM.CODE §51.004 and TEX.R. APP. P. 26.1 on May 18, 2015.

3. Pursuant to TEX. R. APP. P. 35.1(b) and 26.1(b), the clerk’s record for

this interlocutory appeal is due to be filed on or before May 28, 2015. Appellant

believes that there will be no court reporter’s record; and that the only record on

appeal will be the clerk’s record. Appellant timely requested preparation of the

clerk’s record on May 19, 2015, and has made arrangements with the clerk to pay the

applicable fee.

4. Pursuant to Tex. R. App. P. 38.6(a)(1), Appellant’s brief is due to be

filed within 20 days of the filing of the clerk’s record. Assuming the clerk’s record

is timely filed on May 28, 2015, Appellant’s brief will be due on or about June 17,

2015

5. Counsel for Appellant is currently scheduled on a pre-paid, nonrefundable trip to Grand Teton National Park and Yellowstone National Park from

June 5, 2015 until June 15, 2015 for his twenty-fifth wedding anniversary. This trip

has been planned and booked for over three months. During that period, counsel will

not be able to review the record or draft the brief in time to meet a June 17, 2015,

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filing date.

6. Appellant respectfully requests the Court of Appeals to extend the

Appellant’s briefing deadline nine (9) days until June 26, 2015, to enable counsel

time to complete review of the record and draft the brief upon return from his

vacation.

7. The delay will not result in foreseeable prejudice to Appellee or impact

any deadlines in the trial court.

8. This is Appellant’s first request for an extension of time.

9. Appellee is not opposed to this motion.

WHEREFORE, PREMISES CONSIDERED, Appellant Nuria Mandje

respectfully request that the First Court of Appeals grant the requested nine (9) day

extension of time to file Appellant’s brief; and for such other and further relief to

which she may be justly entitled.

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Respectfully submitted,

THE CUNNINGHAM LAW FIRM

 /s/ Scott Douglas Cunningham 

SCOTT DOUGLAS CUNNINGHAM

Texas Bar No. 05243700

7670 Woodway, Suite 110

Houston, Texas 77063

(713) 273-8950

(713) 273-8951 (Fax)

E-mail: sdc1776@peoplepc.com

COUNSEL FOR APPELLANT

CERTIFICATE OF CONFERENCE

The undersigned hereby certifies that counsel for Appellant and counsel for

Appellee conferred on May 21 , 2015, and Appelleesis unopposed to thisrequest for

st

extension of time to file Appellant’s brief.

 /s/Scott Douglas Cunningham 

SCOTT DOUGLAS CUNNINGHAM

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CERTIFICATE OF SERVICE

In accordance with Rule 9.5(e) of the Texas Rules of Appellate Procedure, I

hereby certify that a true and correct copy of the Appellant’s Unopposed Motion to

Extend Time to File Appellant’s Brief has been sent to the following counsel ofrecord

on this 22 day of May, 2015.

nd

Counsel for Appellees

Matthew A. Kornhauser

HOOVER SLOVACEK, LLP

5051 Westheimer Rd., Suite 1200

Houston, Texas 77056

Via Regular First Class Mail

T. Michael Ballases

HOOVER SLOVACEK, LLP

5051 Westheimer Rd., Suite 1200

Houston, Texas 77056

Via Regular First Class Mail

 /s/ Scott Douglas Cunningham 

SCOTT DOUGLAS CUNNINGHAM

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