ACCEPTED 14-16-00587-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/22/2017 3:35 PM CHRISTOPHER PRINE CLERK

No. 14-16-00587-CV

FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS FOR THE FOURTEENTH HOUSTON, DISTRICT TEXAS 12/22/2017 3:35:13 PM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk

DEBBI RATZ, GWEN PATTERSON, AND WENDY BRUNEY, INDIVIDUALS, Appellants,

v.

CATHERINE N. WYLIE, WILLIAM T. POWELL, INDIVIDUALS AND ROBERT LARSON, AS INDEPENDENT EXECUTOR OF THE ESTATE OF GEORGE N. LARSON, JR., DECEASED, Appellees.

On Appeal from the Probate Court of Galveston County, Texas Trial Court Cause No. PR-0075669

APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING

TO THE HONORABLE COURT OF APPEALS:

Appellees respectfully ask this Court to extend the deadline for filing their

motion for rehearing by 30 days, to January 22, 2018. This is the first request for an

extension of time to file this motion.

1. Appellees’ motion for rehearing is due on Friday, December 22, 2017.

2. Appellees’ counsel has devoted time to the preparation of their motion for rehearing, and has engaged additional counsel to assist in its preparation. Its

completion has been delayed, however, by the following circumstances and

conflicts:

a. Drafting and revising a response, filed December 14, to an emergency motion for contempt in an adversary case in a bankruptcy matter in the Southern District of Texas.

b. Year-end settlement negotiations in various trial and appellate court matters during the week of December 18, 2017, including a mediation in Hidalgo County ordered by the trial court to occur on or before December 22, 2017.

c. Scheduling conflicts associated with preparation for the Christmas and New Year holidays.

d. The Christmas and New year holidays. The undersigned counsel’s office is closed the afternoon of December 22, December 25 and 26, and January 1, 2018. The undersigned counsel is also traveling with his family on December 26, 27, and 28, to meet other family members in the Waco area to share in Christmas celebrations.

e. No other obligation has taken precedence over the brief in this case. Counsel has worked and will work with other lawyers to fulfill these responsibilities. The delay in completing this brief has been unavoidable.

3. This request is not made for purposes of delay, but in the interest of

justice. This is the first request for an extension of time regarding this motion.

2 PRAYER

For these reasons, Appellees respectfully request that this Court extend the

deadline for their motion for rehearing by 30 days, to January 22, 2018, and grant

all other relief to which they may be justly entitled.

Respectfully submitted,

William T. Powell State Bar No. 16206800 244 Malone Houston, Texas 77007 713-722-9233 - telephone 713-722-9433 - facsimile Email: [email protected]

Catherine N. Wylie The Wylie Law Firm State Bar No. 24033479 2211 Norfolk Street, Suite 440 Houston, Texas 77098 Email: [email protected] 713-275-8230 - telephone 713-275-8239 – facsimile

/s/ Jeff Nobles Jeff Nobles [email protected] State Bar No. 15053050 SMITH LAW GROUP, LLLP 3700 Buffalo Speedway, Suite 520 Houston, Texas 77098 Telephone: (713) 489-1688 Telecopier: (713) 277-7220

ATTORNEYS FOR APPELLEES

3 CERTIFICATE OF CONFERENCE We have conferred with opposing counsel, and this motion is opposed.

/s/ Jeff Nobles Jeff Nobles

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been sent via e-filing or facsimile to the following counsel on December 22, 2017:

Rudolph M. Culp Horrigan & Goehrs, L.L.P. 5020 Montrose, Suite 500 Houston, Texas 77006

/s/ Jeff Nobles Jeff Nobles

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