Douglas B. Moseley v. Sherrie Arnold ( 2015 )

ACCEPTED 06-15-00031-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 10/12/2015 12:00:00 AM DEBBIE AUTREY CLERK No. 06-15-00031-CV IN THE FILED IN COURT OF APPEALS FOR THE 6th COURT OF APPEALS SIXTH SUPREME JUDICIAL DISTRICT OF TEXASTEXARKANA, TEXAS AT TEXARKANA, TEXAS 10/12/2015 9:21:00 AM DEBBIE AUTREY Clerk DOUGLAS B. MOSELEY, Appellant, vs. SHERRIE ARNOLD, Appellee. Appeal from the 71st District Court of Harrison County, Texas Honorable Brad Morin UNOPPOSED MOTION TO EXTEND APPELLEE’S BRIEFING DEADLINE 1 TO THE HONORABLE COURT OF APPEALS: COMES NOW, Sherrie Arnold, Appellee in the above-captioned proceeding (the “Appellee”), and respectfully submits this Unopposed Motion to Extend Appellee’s Briefing Deadline (the “Motion”). 1. The Appellee respectfully requests an extension of time to file her appellee’s brief for an additional twenty-one (21) days, through and including November 4, 2015. Appellee’s brief is currently due October 14, 2015. This is Appellee’s first request for an extension of briefing deadline in this case. 2. Douglas B. Moseley, the Appellant, consents to the requested extension. 3. Appellee respectfully presents the following facts to the Court as a reasonable explanation for the additional requested extension of time. In addition to preparing the appellee’s brief in this case, counsel for Appellee has been required, and will continue to be required, to devote a substantial amount of time to the following matters: a. Circle Ridge Production, Inc. v. Great Northern Energy, et al., Cause No. 14- 0460 in the 71st Judicial District Court of Harrison County, Texas: Counsel for Appellee is counsel for Plaintiff Circle Ridge Production, Inc. and Counter/Cross-Defendant Bill Briscoe in this Trespass to Try Title, or in the alternative, Suit to Quiet Title. The case is specially set for jury trial on October 19, 2015 before the Honorable Brad Morin. b. Mary Stevens v. AdCorp Outdoor Media, L.L.C., Cause No. 15-0258 in the 71st Judicial District Court of Harrison County, Texas: Counsel for Appellee is counsel for Plaintiff Mary Stevens in this Declaratory Judgment and Trespass, or, in the alternative, Partition of Property, and for Injunctive Relief. This case is set for bench trial before the Honorable Brad Morin on October 27, 2015. 4. The requested enlargement of time, which is unopposed, is not sought for the sake of delay, but rather is requested for the minimum amount of time necessary for counsel to properly prepare Appellee’s Brief in this matter. 2 Therefore, Appellee prays that this Court grant this Motion for extension of time to extend the due date for appellee’s brief for twenty-one (21) days until November 4, 2015. Respectfully submitted, DEAN A. SEARLE Texas Bar No. 17956600 RONAN S. SEARLE Texas Bar No. 24079292 SEARLE & SEARLE, PC P.O. Box 910 305 West Rusk Street Marshall, Texas 75671 Phone (903) 935-9772 Fax (903) 935-9790 Dsearle54@gmail.com Ronan.searle@gmail.com By: /s/ Ronan S. Searle Ronan S. Searle Texas Bar No. 24079292 ATTORNEYS FOR THE APPELLEE . CERTIFICATE OF CONFERENCE I hereby certify that, on September 30, 2015, I conferred with Gerrit M. Pronske, counsel for Appellant, who indicated that Appellant is unopposed to the extension requested herein. /s/ Ronan S. Searle Ronan S. Searle 3 CERTIFICATE OF SERVICE I, the undersigned, hereby certify that, on October 11, 2015, I caused to be served the foregoing pleading upon the counsel listed below via email and also via the Court’s electronic transmission facilities. Gerritt M. Pronske Melanie P. Goolsby PRONSKE GOOLSBY & KATHMAN, P.C. 15305 Dallas Parkway, Suite 300 Addison, Texas 75001 Email: gpronske@pgkpc.com Email: mgoolsby@pgkpc.com /s/ Ronan S. Searle Ronan S. Searle 4