TWENTY-SECOND JUDICIAL DISTRICT

PARISH OF ST. TAMMANY

STATE OF LOUISIANA

NUMBER: 2010-11570 DIVISION: “L”

ANDRE M. CHEVELIER

VERSUS

NATALIE REESE

FILED: ______________________ DEPUTY CLERK: _________________

MOTION FOR EXTENSION OF TIME

NOW INTO COURT, through the undersigned counsel, comes Mover, NATALIE

REESE, who respectfully represents to this Honorable Court that a Notice of Intent was filed and

signed by this Honorable Court on or about May 26, 2011, which allowed undersigned counsel

until June 24, 2011 to file an Application for Writs with the Louisiana First Circuit Court of

Appeal; that the undersigned counsel seeks additional time in which to file said Writ Application

because he will not be able to obtain a transcript of the proceedings needed for the preparation of

the writs; that said transcripts are paid for and schedule for delivery this week; and that

accordingly, undersigned counsel respectfully requests and additional 30 days within which to

filed said Writ Application.

Respectfully submitted,
 ____________________
RUSSELL STEGEMAN
Attorney for Defendant
BAR NO: 08224
209 Highway 22 Suite G
West Madisonville, LA 70447
Phone/ Fax (877) 925-5297

ORDER

Considering the above and foregoing:

IT IS ORDERED that Mover, NATALIE REESE, be and is hereby granted an additional

twenty (20) days, or until the ____ day of _____ 20___, within which to file said Writ

Application with the First Circuit Court of Appeal.

COVINGTON, LOUISIANA, this _____ day of _____ 20____

_________________________
JUDGE