No. [insert appellate court number]

IN The Fourteenth Court of Appeals
houston, Texas

[insert appellant’s name],

Appellant,

V.

[insert appellee’s name],

Appellee.

First [Unopposed] Motion for Extension of Time
to File Appellant/appellee’s brief

[insert name and address]

TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant/Appellee, [insert appellant’s name], files this Unopposed First Motion to Extend Time to File Appellant’s Brief.

Appellant/Appellee’s opening brief is currently due on (date).

Counsel for Appellant/Appellee requests a 30-day extension of time to file its brief, making the brief due on (date). This is the first request for extension of time to file the opening brief.

Counsel for Appellant/Appellee relies on the following reasons, in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the requested extension [suggested alternatives]:

[Insert the reasons you need the extension, which may include the following:]

Counsel for Appellant/Appellee has been preparing briefs in the following cases…

Counsel for Appellant/Appellee has primary responsibility in the following lawsuits which involve [explain nature of conflicting work]…

Counsel has been recently appointed by the Court to represent Appellant/Appellee in accordance with the State Bar of Texas and Houston Bar Association Pro Bono Program and needs additional time to familiarize him/herself with the record and legal issues in the case in order to prepare Appellant/Appellee’s brief.

Counsel has undergone recent medical procedures and is currently on medical leave from his practice. As a result, he will not be able to prepare the brief in time to meet the Court’s briefing deadline absent an extension.

Counsel for Appellant/Appellee seeks this extension of time to be able to prepare a cogent and succinct brief to aid this Court in its analysis of the issues presented. This request is not sought for delay but so that justice may be done.

The undersigned has conferred with opposing counsel, and he/she has indicated that his/her client does not oppose this motion. [If this is correct, then add the word UNOPPOSED to the title of this motion for extension of time to file your brief.]

All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellant/Appellee requests that this Court grant this Unopposed First Motion to Extend Time to File Appellant/Appellee’s Brief and extend the Deadline for Filing the Appellant/Appellee’s Brief up to and including [insert date]. Appellant/Appellee all other relief to which it may be entitled.

Respectfully submitted,

____________________________________

Name and Address of Filing Attorney

Counsel for Appellant/Appellee


Certificate of Conference

I certify that I conferred with counsel for Appellee/Appellant regarding this motion and that Appellee/Appellant [is/is not] opposed to this motion.

[insert Appellant’s/Appellee’s name]

Certificate of Service

I certify that on [insert date], I mailed a copy of this motion to the following counsel by First Class U.S. Mail [or another acceptable method of service]:

[insert name and address of Appellee’s/Appellant’s counsel]

Counsel for Appellee/Appellant

[insert Appellant’s/Appellee’s name]