No. 03-15-00667-CV IN THE COURT OF APPEALS THIRD DISTRICT OF TEXAS

AT AUSTIN

________________________________________________________________________ NASIM IQBAL, TEJ IQBAL, AND/OR OCCUPANTS OF 2503 PADEN CIRCLE, CEDAR PARK, TEXAS 78613

Appellants v. FEDERAL NATIONAL MORTGAGE ASSOCIATION , Appellee

________________________________________________________________________ On Appeal from the County Court at Law No. 4 of Williamson County, Texas

Cause No. 15-0444-CC4

________________________________________________________________________ APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

________________________________________________________________________
TO THE HONORABLE COURT: COMES NOW the Appellants, Nasim Iqbal, Tej Iqbal, and/or Occupants of 2503 Paden Circle, Cedar Park, Texas 78613 (“The Iqbals”), and file this their Motion for Extension of Time to File Appellant’s Brief, and in support thereof would show the court as follows: 1. This case is an appeal from a final judgment in the County Court at Law No. 4 of Williamson County, Texas. The Iqbals are the appellants. Federal National Mortgage Association is the appellee.
1 ACCEPTED 03-15-00667-CV 8103311 THIRD COURT OF APPEALS

AUSTIN, TEXAS 12/4/2015 4:53:23 PM JEFFREY D. KYLE

CLERK2. The cl e r k ’ s r e c o r d in this case was f iled on Novem

ber 2, 2015, and the reporter’s record in this case was f

iled on Novem

ber 30, 2 0 1 5

. U n d e r the current brief ing schedule, The Iqbals’ brief

is due on W ednesday , Decem ber 30, 2015. T E X
. R. A P P
. P. 38.6(a).
3. Lead Counsel f

or appellant, Mr. Scott Placek, will be out of the of f ice in Decem

ber due to an illness in his f

am ily and the Christm as h o l i d a y s. Due to that travel, Mr. Placek requires m ore tim e to review the clerk’s record and reporter’s record in this case and prepare the appellant’s brief

. 4. Counsel f

or appellant was retained by the Iqbals on October 16, 2015, less than a week bef ore their notice of appeal was due in this Court. The county court did not provide counsel with the reporter’s record until it was f iled in this Court on Novem ber 30, 2015. As

a result, counsel requires m ore tim e to review the clerk’s record and reporter’s record in this case and prepare the appellant’s brief

. 5. The Iqbals ask that this Court grant a 30-day extension to f ile their appellant’s brief

. The Iqbals’ appellant’s brief would be due by

Friday , January

29, 2016.
6. The Iqbals have not previously requested a m odif ication to the brief

ing s c hedule in this m atter. 7. The Iqbals’ requested m odif ication is f

or good cause, is not sought s o l e ly f or the purposes of

delay , and is sought to prom ote judicial ef f iciency

. 8. Counsel f

or appellee Federal National Mortgage Association w a s c o ntacted by counsel f or The Iqbals but did not state whether they opposed the m otion.

2W H EREFORE, PREMISES CONSIDERED, The Iqbals respectf ully reque s t t

h a t t h i s Court gran t t h i s M otion f or Extension of Tim e to File Appellant’s Brief and extend the deadline f or The Iqbals to f

ile their brief

to January

29, 2016.

Respectf ully Subm itted, ARNOLD & PLACEK, P.C. 203 East Main Street, Suite 201 Round Rock, Texas 78664 Telephone:(512) 341-7044 Facsim ile:(512) 341-7921
By :

_ /s/ J onathan Chaltain

______ R. SC OTT PL ACEK State Ba

r No. 00784769 splace k@arnoldplac ek.com SCOTT K. ARNOL D State Ba

r No. 00785669 sarnold@a

rnoldplace k.com J ONATH AN CHAL TAI N State Ba

r No. 24079787 jchaltain@a

rnoldplace k.com

A TT O R N E Y S F O R

A P P E L L A N T N A S I M I Q B A L , T E J I Q B A L , A N D / O R O C C U P A

N TS O F 2503 P A D E

N C I R C L E , C E D A R P A R

K , T E X A S 76813

3CERTIFICATE OF CONFERENCE

I hereby certif

y that I reasonably attem

pted to conf

er with appellee’s counsel but did not receive a response as to whether the motion is opposed.

_ /s/ J onathan Chaltain

________ Jonathan Chaltain

4CERTIFICATE OF SERVICE

I hereby certif

y that a true and correct copy of the above and f oregoing docum ent has been f orwarded to the f

ollowing A p pellee’s attorney s of record by f acsim ile and e-service on this 4 th day

of Decem ber, 2015.
J eff ry B. L ewis VI A FA CSI MI L E AND E- SERVI CE Robertson Anshutz Vetters 10333 Richmond Avenue, Suite 550 Houston Texas 77042 Fa csimile: (713) 888-2703 jlewis@ravdoc s.com Br ian P. Casey VI A FA CSI MI L E AND E- SERVI CE Doug las G. De nt 6836 Be e Cave s Rd Bldg 3, Suite 303 Austin, Texas 78746 Fa csimile: (888) 530-9616 bcasey @casey lawtx.com

_ /s/ J onathan Chaltain

__________ Jonathan Chaltain

5