Court of Civil Appeals of Texas, 2015

Sunny Letot v. United Services Automobile Association

Sunny Letot v. United Services Automobile Association
Court of Civil Appeals of Texas · Decided March 5, 2015

Sunny Letot v. United Services Automobile Association

Opinion

ACCEPTED 05-14-01394-cv FIFTH COURT OF APPEALS DALLAS, TEXAS 3/5/2015 10:56:01 AM LISA MATZ CLERK NO. 05­14­01394­CV IN THE COURT OF APPEALS FOR THE FIFTH DISTRICT OF TEXAS FILED IN 5th COURT OF APPEALS _________________________________________________________________ DALLAS, TEXAS 3/5/2015 10:56:01 AM SUNNY LETOT, LISA MATZ Clerk Appellant V. UNITED SERVICES AUTOMOBILE ASSOCIATION, Appellee _________________________________________________________________ Appeal from the 1 92th Judicial District Court of Dallas County, Texas Trial Court Cause No. 13­00156­B _________________________________________________________________ APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF _________________________________________________________________ TO THE HONORABLE COURT OF APPEALS: Appellant Sunny Letot (“Appellant”) files this Unopposed Motion for Extension of Time to File Brief (the “Motion”), and in support thereof, would show as follows: I. DUE DATE 1. Appellant’s brief is currently due today, March 5, 2015.

2. Appellant seeks an additional seven (7) days to file its Brief until Thursday, March 12, 2015.

II. REASON FOR EXTENSION OF TIME 3. Appellant’s requested extension is necessary because of the inclement weather conditions in the Dallas metroplex, resulting in the closing of counsel for Appellant’s offices. In addition, Appellant’s counsel has been actively been engaged in other previously­scheduled matters that have prevented the timely completion of Appellant’s Brief.

4. These and other professional commitments have prevented the timely completion of Appellant’s Brief, necessitating the requested extension of seven (7) days to file Appellant’s Brief.

5. This is Appellant’s first request for a seven­day extension and the request is unopposed.

III. EXTENSION SOUGHT IN THE INTEREST OF JUSTICE 6. Appellant’s Motion is not brought to cause undue delay but for good cause and so that justice may be done.

IV. APPELLEE DOES NOT OPPOSE THIS MOTION 7. On March 5, 2015, counsel for Appellant conferred with counsel for Appellee regarding the contents of this Motion, and counsel for Appellee stated that he does not oppose this Motion.

V. PRAYER FOR EXTENSION For the reasons stated above, Appellant Sunny Letot respectfully requests that this Unopposed Motion for Extension of Time to File Brief be granted, and that the deadline to file Appellant’s Brief be extended by seven (7) days until Thursday, March 12, 2015. Appellant further requests all such other relief to which she may be justly entitled.

Date: March 5, 2015 Respectfully submitted,

/s/Jeffrey M. Tillotson Jeffrey M. Tillotson Texas Bar No. 20039200 [email protected] LYNN TILLOTSON PINKER & COX, LLP 2100 ​ Ross Avenue Suite 2700 Dallas, Texas 75201 (214) 981­3800 (214) 981­3838 Facsimile ATTORNEYS FOR APPELLANT CERTIFICATE OF CONFERENCE On March 5, 2015, I contacted Robert Owen, counsel for Appellee, regarding the contents of this Motion, and Mr. Owen stated that he does not oppose this Motion.

/s/Jeffrey M. Tillotson Jeffrey M. Tillotson

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF was served upon the following counsel for the parties in accordance with the Texas Rules of Appellate Procedure on March 5, 2015.

Robert T. Owen Texas Bar No. 24060370 owen@rndjwlaw. corn Levon G. Hovnatanian Texas Bar No. 10059825 [email protected] MARTIN, DIsIERE, JEFFERSON & WISDOM L.L.P. Travis, 20th Floor Houston, Texas 77002 (713) 632­1700 — Telephone (713) 222­0101 — Facsimile /s/Jeffrey M. Tillotson Jeffrey M. Tillotson

Case-law data current through December 31, 2025. Source: CourtListener bulk data.