JDH Pacific, Inc. v. Precision-Hayes International, Inc.
Whether the Supreme Court should grant an extension of time to file a petition for a writ of certiorari based on personal family circumstances
No question identified. : for his Mum, Counsel is also seeking amicus support from a noted university professor who has written frequently concerning the subject of the petition. Additionally, Petitioner’s counsel is defending a request for a temporary injunction, prosecuting an action for declaratory judgment concerning insurance coverage, defending an Opposition before the Trademark Trial & Appeal Board, and various other client matters. Counsel has a heavy caseload and requires additional time to prepare the petition for a writ of certiorari. Undersigned counsel contacted Respondent’s counsel and Respondent OPPOSES Petitioner’s Request for a sixty-day extension (or any extension). This request is not made lightly or for purposes of delay, but to allow Counsel to help his Mum in whatever remaining time she has. Conclusion WHEREFORE, Petitioner respectfully submits that the Court should grant Petitioner a 60-day extension of time from November 16, 2023 until January 15, 2024 to file its Petition for a Writ of Certiorari. Respectfully submitted, /s/Malcolm E. Whittaker Malcolm E. Whittaker Counsel of Record Petitioner JDH Pacific, Inc. Whittaker Law Firm 2341 Glen Haven Boulevard Houston, Texas 77030 IPLitigate@aol.com 832-434-7157 Certificate of Service A copy of this application was served by email and U.S. Mail to counsel listed below in accordance with Supreme Court Rule 22.2 and 29.3 on October 30, 2023: John M. Zukowski jmz@zbplaw.com Pascal Paul Piazza ppp@zbplaw.com Zukowski, Bresenhan & Piazza, L.L.P. 1177 West Loop South, Suite 950 Houston, Texas 77098; and, Marcy Hogan Greer mgreer@adjtlaw.com Alexander Dubose & Jefferson LLP 515 Congress Avenue, Suite 2350 Austin, Texas 78701 and, Michael D. Morfey Hunton Andrews Kurth 600 Travis Street Suite 4200 Houston, Texas 77002 K.com Attorneys for Respondent Respectfully submitted, /s/Malcolm E. Whittaker Malcolm E. Whittaker Counsel of Record Petitioner JDH Pacific, Inc. Whittaker Law Firm 2341 Glen Haven Boulevard Houston, Texas 77030 IPLitigate@aol.com 832-434-7157