No. 14-14-00927-CV 

 

In the 

Fourteenth Court of Appeals at Houston, Texas 

 

ULRIKA BJORKSTAM AND JOSEPH DANIEL DRAY, 

Appellants, 

v. 

WOODWARD, INC., 

Appellee. 

On Appeal from the 190th Judicial District Court Of 

Harris County, Texas 

Trial Cause No. 2010-31214 

The Honorable Patricia J. Kerrigan, Presiding 

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLANTS’ REPLY BRIEF 

Appellants Ulirka Bjorkstam and Joseph Daniel Dray file their Unopposed 

Motion for Extension of Time to File Appellants’ Reply Brief, pursuant to Tex. R. 

App. P. 10.5(b). 

1. Presently, Appellants’ Reply Brief is due July 15, 2015. 

2. Through this Unopposed Motion, Appellants seek an extension of 

fourteen (14) days to file their Reply Brief. Should the Court grant this Motion, 

the new deadline will be July 29, 2015. 

3. This Motion is timely, pursuant to Tex. R. App. P. 38.6(d). 

ACCEPTED

14-14-00927-cv

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

7/15/2015 2:28:00 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 2:28:00 PM CHRISTOPHER A. PRINE Clerk
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4. The requested extension of time is necessary because the undersigned 

has a heavy docket, including substantial involvement in the following matters: 

Case No. C2012-7881; Jefi Jeannette Ochoa, et al. v. Giti Tire 

Corporation, et al.; in the Superior Court of the State of Arizona in 

and for the County of Pima – hearing on Giti Tire (Fujian) Co., Ltd.’s 

and Giti Tire Corporation’s Motions to Dismiss for Lack of 

Jurisdiction – occurred on July 10, 2015; 

Cause No. L-13-0061-CV-B; Texas Crude Energy, LLC and Amber 

Harvest, LLC v. Burlington Resources Oil & Gas Company LP; in the 

156th District Court of Live Oak County, Texas – preparation of 

Plaintiffs’ Motion for Reconsideration by the Court of Written 

Findings and Recommendations of the Master in Chancery with 29 

Exhibits that total 679 pages – filed on July 13, 2015. 

5. The requested extension is therefore necessary to allow Appellants 

adequate time to prepare their Reply Brief. The request for additional time is not 

made for delay, but only so that justice may be done. 

6. These facts are within personal knowledge of the undersigned. 

Therefore, verification is unnecessary. Tex. R. App. P. 10.2. 

7. Appellee’s counsel has no objection to the requested extension of 

fourteen (14) days. Therefore, should the Court grant this Motion, the extension 

will not result in undue hardship or material harm to Appellee. 

For these reasons, Appellants request that the Court grant their Unopposed 

Motion for Extension of Time to File Appellants’ Reply Brief. 

 
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Respectfully submitted, 

PIERCE & O’NEILL, LLP 

/s/ John C. Schwambach, Jr. 

John C. Schwambach, Jr. 

Texas State Bar Number 17858450 

4203 Montrose Boulevard 

Houston, Texas 77006 

713-634-3607 Direct 

713-634-3600 Main 

713-634-3601 Facsimile 

jschwambach@pierceoneill.com

 Attorney for Appellants 
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CERTIFICATE OF CONFERENCE 

I, John C. Schwambach, Jr., counsel for Appellants, Ulrika Bjorkstam and 

Joseph Daniel Dray, hereby certify that I have conferred with Terry Adams, 

counsel for Appellee, about the merits of this Motion, and he is unopposed to this 

Motion. 

 /s/ John C. Schwambach, Jr. 

John C. Schwambach, Jr. 

 
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CERTIFICATE OF SERVICE 

 Pursuant to the Texas Rules of Appellate Procedure, I hereby certify that a 

true and correct copy of the foregoing was electronically filed and served upon all 

know counsel of record this 15th day of July, 2015. 

John Michael Kelly 

(admitted pro hac vice) 

jkelly@amm-law.com

Gina Marie Diomedi 

(admitted pro hac vice) 

gdiomedi@amm-law.com

Christine Marie Niemczyk 

(admitted pro hac vice) 

cniemczyk@amm-law.com

ADLER MURPHY & MCQUILLEN LLP 

20 South Clark Street, Suite 2500 

Chicago, Illinois 60603 

Telephone: (312) 345-0700 

Facsimile: (312) 345-9860 

N. Terry Adams, Jr. 

tadams@bmpllp.com

BIERNE, MAYNARD & PARSONS,

L.L.P. 

1300 Post Oak Boulevard, 25th Floor 

Houston, Texas 77056 

Telephone: (713) 623-0887 

Facsimile: (713) 960-1527 

 

/s/ John C. Schwambach, Jr. 

John C. Schwambach, Jr. 

908608.1