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.

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ACCEPTED

03-15-00667-CV

8103311

THIRD COURT OF APPEALS

AUSTIN, TEXAS

12/4/2015 4:53:23 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/4/2015 4:53:23 PM JEFFREY D. KYLE Clerk
2. The clerk’s record in this case was filed on November 2, 2015, and the reporter’s

record in this case was filed on November 30, 2015. Under the current briefing schedule,

The Iqbals’ brief is due on Wednesday, December 30, 2015. TEX. R. APP. P. 38.6(a).

3. Lead Counsel for appellant, Mr. Scott Placek, will be out of the office in December

due to an illness in his family and the Christmas holidays. Due to that travel, Mr. Placek

requires more time to review the clerk’s record and reporter’s record in this case and prepare

the appellant’s brief. 

4. Counsel for appellant was retained by the Iqbals on October 16, 2015, less than a 

week before their notice of appeal was due in this Court. The county court did not provide

counsel with the reporter’s record until it was filed in this Court on November 30, 2015. As

a result, counsel requires more time 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 file 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 modification to the briefing schedule in

this matter.

7. The Iqbals’ requested modification is for good cause, is not sought solely for the

purposes of delay, and is sought to promote judicial efficiency.

8. Counsel for appellee Federal National Mortgage Association was contacted by

counsel for The Iqbals but did not state whether they opposed the motion.

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WHEREFORE, PREMISES CONSIDERED, The Iqbals respectfullyrequestthatthis

Court grant this Motion for Extension of Time to File Appellant’s Brief and extend the

deadline for The Iqbals to file their brief to January 29, 2016.

Respectfully Submitted,

ARNOLD & PLACEK, P.C.

203 East Main Street, Suite 201

Round Rock, Texas 78664

Telephone:(512) 341-7044

Facsimile:(512) 341-7921

By: _/s/ Jonathan Chaltain______

 R. SCOTT PLACEK

 State Bar No. 00784769

 splacek@arnoldplacek.com

 SCOTT K. ARNOLD

 State Bar No. 00785669

 sarnold@arnoldplacek.com

 JONATHAN CHALTAIN

 State Bar No. 24079787

 jchaltain@arnoldplacek.com

 

ATTORNEYS FOR APPELLANT

NASIM IQBAL, TEJ IQBAL, AND/OR

OCCUPANTS OF 2503 PADEN CIRCLE,

CEDAR PARK, TEXAS 76813

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CERTIFICATE OF CONFERENCE

I hereby certify that I reasonably attempted to confer with appellee’s counsel but did

not receive a response as to whether the motion is opposed.

_/s/ Jonathan Chaltain________

Jonathan Chaltain

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CERTIFICATE OF SERVICE

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

been forwarded to the following Appellee’s attorneys of record by facsimile and e-service

on this 4th day of December, 2015.

Jeffry B. Lewis VIA FACSIMILE AND E-SERVICE

Robertson Anshutz Vetters

10333 Richmond Avenue, Suite 550

Houston Texas 77042

Facsimile: (713) 888-2703

jlewis@ravdocs.com

Brian P. Casey VIA FACSIMILE AND E-SERVICE

Douglas G. Dent

6836 Bee Caves Rd

Bldg 3, Suite 303

Austin, Texas 78746

Facsimile: (888) 530-9616

bcasey@caseylawtx.com

_/s/ Jonathan Chaltain__________

Jonathan Chaltain

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