which would make Appellant's Brief due on or before May 4,2015.

1

2. Appellant seeks a 20-day day extension of time to file Appellant's Brief,

1. Appellant's Reply Brief is due to be filed with this court on April 14,

2015.

time to file Appellant's Reply Brief, and respectfully states:

LETICIA LoyA, Appellant, moves this Court to grant an extension of

TO THE HONORABLE FIRST COURT OF APPEALS:

UNOPPOSED FIRST MOTION TO EXTEND

TIME FOR FILING APPELLANT'S REPLY BRIEF

Appeal from the 190th Judicial District Court, Harris County, Texas

Trial Court Cause No. 2012-33464

IANTAYLOR,JACOBUSSTERKEN,STICHTINGTINSELGROUP,VITOL

HOLDINGII S.A., AND TINSELGROUP,S.A.,

Appellees.

LETICIALoy A,

Appellant,

IN THE COURTOF ApPEALS

FOR THEFIRSTDISTRICTOFTEXAS

AT HOUSTON

No.01-14-01014-CV

v.

ACCEPTED

01-14-01014-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/1/2015 2:12:04 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/1/2015 2:12:04 PM CHRISTOPHER A. PRINE Clerk
render an order extending the time for filing Appellant's Reply Brief to and

For these reasons, LETICIA Loy A, Appellant, requests that this Court

the Appellant's Reply Brief.

5. This is the first extension of time Appellant has sought for the filing of

Tinsel Group, S.A., and Appellees do not oppose this motion to extend time.

Taylor, Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and

4. Counsel for Appellant has conferred with counsel for Appellees Ian

additional time is needed to adequately prepare the arguments in this case.

but rather to afford counsel adequate time to prepare the brief. Therefore,

reply brief in this appeal. This request is not filed for the purpose of delay,

As a result, time constraints will make it difficult to adequately prepare the

• Universal Gold Coin v. FedEx et al, Western District of Tennessee

(Daubert and pre-trial motions)

• Filer v. Keystone Corporation, New York State Supreme Court,

(pretrial motions and hearings)

• Altamirano v. KONE, 136th Judicial District of Texas (eleven

depositions, discovery deadline approaching)

• Raja v.Kolander, 172nd Judicial District of Texas (trial)

• Reado v. Lopez, 136th Judicial District of Texas (trial)

deadlines prior to April 14, 2015 deadline, including but not limited to:

was/is participating in several oral arguments, appeals and/or trials with

3. This extension of time is necessary because lead counsel for Appellant

2
3

Jennifer Job

/ s / Jennifer Job

I hereby certify that a copy of this motion to amend notice of appeal

has been sent to all known counsel of record via EFILE and/or certified

mail, return receipt requested on April 1, 2015.

CERTIFICATEOF SERVICE

I hereby certify that I conferred with counsel for Appellees Ian Taylor,

Jacobus Sterken, Stichting Tinsel Group, Vitol Holding II S.A., and Tinsel

Group, S.A. concerning this motion, and Appellees do not oppose the relief

requested in this motion.

CERTIFICATE OF CONFERENCE

By: / s / Jenniter Job

Jennifer Job

Texas State Bar No. 24050682

James Payne

Texas State Bar No. 00788171

ATTORNEYS FOR APPELLANT

PROVOST*UMPHREY LAW FIRM,

L.L.P.

490 Park Street

P. O. Box 4905

Beaumont, Texas 77704

(409) 835-6000

(409) 813-8682 (FAX)

Respectfully submitted,

may be entitled.

including May 4, 2015. Appellant also requests any other relief to which she

/ s / Jennifer Job