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NO. 01-14-00455-CV 

 (APPEAL NO. 1; APPEAL NO. 2; AND APPEAL NO. 3) 

_________________________________________________________________ 

 IN THE COURT OF APPEALS 

 FOR THE FIRST SUPREME JUDICIAL DISTRICT OF TEXAS 

 AT HOUSTON, TEXAS 

_________________________________________________________________ 

 PHILIPPE TANGUY, 13500 AIR EXPRESS, L.L.C., AND 

 13500 AIR EXPRESS, L.P., 

 Appellant/Defendant, 

VS. 

 PTRE HOLDINGS, L.P. 

 Appellant/Intervenor, 

VS. 

 WILLIAM G. WEST, AS CHAPTER 7 TRUSTEE OF RICHARD DAVIS, DEBTOR 

 Appellee/Plaintiff. 

_________________________________________________________________ 

 APPELLANTS' MOTION TO ENLARGE TIME WITHIN WHICH TO FILE

 REPLY BRIEF

_________________________________________________________________ 

TO THE HONORABLE JUSTICES OF SAID COURT OF APPEALS: 

COME NOW, the Appellants, Philippe Tanguy ("TANGUY"), 13500 Air 

Express, LLC, 13500, Air Express, LP, ("13500") and PTRE Holdings, 

L.P. ("PTRE"), and file this Motion to Enlarge Time Within Which 

to File their Reply Brief and, in support of this motion, would show 

the Court the following: 

1. The Opening Brief by Appellants and Response Brief by Appellee 

ACCEPTED

01-14-00455-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

1/22/2015 7:03:06 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 1/22/2015 7:03:06 PM CHRISTOPHER A. PRINE Clerk
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were timely filed. The Appellants' Reply Brief is due to be filed 

on January 22, 2015. 

2. However, Appellants' counsel, Joe Alfred Izen, Jr., has been 

ill since January 11, 2015 with fever and inflammatory symptoms. 

Izen tried to keep working on the Reply Brief over the time he was 

suffering these increased symptoms, and hoped to complete and file 

it by January 22, 2015. 

3. Izen became worse and developed an increased fever which went 

up to 101 degrees on Wednesday, January 21, 2015. Izen has been 

unable to walk without crutches for the past ten (10) days. 

4. Appellants' counsel hopes to recover from his illness and 

complete the reply brief within two weeks. Izen has scheduled an 

appointment with his internist, Dr. Wm. E. Obernour, on Friday, 

January 23, 2015 to undergo further evaluation and treatment. 

5. This enlargement of time is sought not for the purposes of 

delay only, but so that Justice may be done. Counsel's medical 

condition has made a request for enlargement necessary. 

6. Appellants sought one previous enlargement on this appeal 

to file his original brief. Appellants filed their Opening Brief 

within the enlargement granted by this Court. 

7. No other enlargement of time to file the Reply Brief has been 

sought or granted. 

WHEREFORE, ABOVE PREMISES CONSIDERED, Appellants move this Court 
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to entertain this Motion and, after due consideration of same, that 

this Court enter an Order: (1) Enlarging the time within which 

Appellants may file their Reply Brief with this Court to and until 

February 5, 2015; and (2) Granting Appellants such other and further 

relief, both in law and in equity, to which they may show themselves 

to be justly entitled. 

Respectfully submitted, 

s/Joe Alfred Izen, Jr. 

__________________________ 

Joe Alfred Izen, Jr. 

TBC # 10443500 

5222 Spruce Street 

Bellaire, Texas 77401 

(713) 668-8815 

(713) 668-9402 FAX 

jizen@comcast.net 

Attorney for Appellants Philippe 

Tanguy, 13,5000 Air Express L.P. 

And 13,500 Air Express L.L.C. 

s/Joe Alfred Izen, Jr. 

____________________________ 

Joe Alfred Izen, Jr. 

TBC # 10443500 

5222 Spruce Street 

Bellaire, Texas 77401 

(713) 668-8815 

(713) 668-9402 FAX 

jizen@comcast.net 

Attorney for Appellant PTRE 

Holdings, L.P. 
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 CERTIFICATE OF CONFERENCE

Mr. Wolfshol was contacted via email and gave no position although 

he did send a "read receipt acknowledgement" of the email. 

s/Joe Alfred Izen, Jr. 

_______________________ 

Joe Alfred Izen, Jr. 

 CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing document 

was sent to Joshua W. Wolfshohl, Porter and Hedges, 1000 Main Street, 

36th Floor, Houston, TX 77002, (713) 226-6231 FAX by eservice 

transmission and/or U.S. Mail, postage prepaid, on January 22, 2015. 

s/Joe Alfred Izen, Jr. 

_______________________________ 

 Joe Alfred Izen, Jr. 

TANGWESTA.M2E/TK471 
 

 VERIFICATION

STATE OF TEXAS ) 

 ) 

COUNTY OF HARRIS ) 

BEFORE ME, the undersigned authority, on this day personally 

appeared Joe Alfred Izen, Jr., known to me to be the attorney for 

Appellants, who after being by me duly sworn, on his oath, did depose 

and testify that he had read the foregoing document, that all of 

the facts stated therein are true and correct and within his own 

personal knowledge. 

s/Joe Alfred Izen, Jr. 

_______________________________ 

Joe Alfred Izen, Jr. 

SUBSCRIBED AND SWORN TO on this the 22nd day of January, 2015, 

to certify which witness my hand and seal of office. 

s/Karen Cooley 

 ______________________________ 

 Public In and For 

 The State of Texas 

My commission expires: 

 6-21-2018 SEAL 

______________________