City of Fort Worth, Texas v. Mary Deal ( 2017 )

ACCEPTED 02-17-00413-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 12/21/2017 2:55 PM DEBRA SPISAK CLERK No. 02-17-00413-CV FILED IN 2nd COURT OF APPEALS City of Fort Worth, Texas, * In the Court of Appeals FORT WORTH, TEXAS 12/21/2017 2:55:54 PM Appellant * DEBRA SPISAK vs. * Second District of Clerk Texas Mary Deal, * Appellee * Fort Worth, Texas APPELLEE'S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF Appellant City of Fort Worth, Texas, filed its brief in this accelerated appeal on December 20, 2017. Under TRAP Rule 38.6, the brief of Appellee Mary Deal is due to be filed by January 9, 2018. In accord with TRAP Rule 10.5(b)(1) and the Internal Operating Procedures of this Court, Appellee requests the Court to grant a 20-day extension of the deadline for filing her brief, until January 29, 2018. This extension is requested in part because Appellee's counsel (the undersigned) has various other obligations and plans during the upcoming holidays, ending January 2, 2018. Further, as a solo practitioner handling a case in an area of the law previously unfamiliar to him, Appellee's counsel needs additional time to assure a thorough yet succinct response to Appellant's just-filed brief. Appellee has not received any previous extensions of her briefing deadline, and Appellant does not oppose Appellee's request. Respectfully submitted, /s/ Joe Riddell Joe Riddell Texas Bar No. 16886500 PO Box 41898 Austin, Texas 78704 email: joeriddell@aol.com phone: 512-663-4669 fax: none Attorney for Appellee, Mary Deal CERTIFICATE OF CONFERENCE By my signature below, I, Joe Riddell, counsel for Appellee, certify that on December 20, 2017, I conferred with Laetitia Brown, counsel for Appellant, regarding the 20-day extension requested in this Motion, and she does not oppose it. /s/ Joe Riddell CERTIFICATE OF SERVICE By my signature below, I, Joe Riddell, counsel for Appellee, certify that I am serving the foregoing APPELLEE'S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF by emailing it via the efile.txcourts portal to Laetitia Brown, counsel for Appellant, at laetitia.brown@fortworthtexas.gov on December 21, 2017. /s/ Joe Riddell