Craig A. Washington v. Commission for Lawyer Discipline ( 2015 )

ACCEPTED
03-15-00083-CV
6276625
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/29/2015 2:54:52 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00083-CV
___________________________________________________________
FILED IN
3rd COURT OF APPEALS
In the Third District Court of Appeals AUSTIN, TEXAS
Houston, Texas 7/29/2015 2:54:52 PM
___________________________________________________________
JEFFREY D. KYLE
Clerk
CRAIG A. WASHINGTON,
Appellant,
vs.
COMMISSION FOR LAWYER DISCIPLINE,
Appellee.
___________________________________________________________
UNOPPOSED SECOND MOTION OF CRAIG A. WASHINGTON TO
EXTEND DEADLINE FOR PRINCIPAL BRIEF
___________________________________________________________
Appellant Craig A. Washington asks that this Court extend for fourteen
(14) days the deadline for the filing of his principal brief as the appellant in the
above-captioned case, making the new briefing deadline August 17, 2015. In
support Mr. Washington states:
1. This is an appeal from a final judgment signed January 8, 2015. The
completed clerk’s record was filed June 2, 2015, and the reporter’s record was
filed May 15, 2015. Therefore, the principal brief of the appellant is was initially
due July 2, 2015. TEX. R. APP. P. 38.6(a). This court can extend that deadline, and
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has extended it to August 3, 2015. Id. 38.6(d). This is the appellants’ second
request to extend the deadline, and it is unopposed.
2. Counsel for Mr. Washington, John MacVane, is principally
responsible for drafting the brief and was trial counsel in urgent temporary
restraining order and temporary injunction proceedings in Berry GP, Inc. v. BTB
Refining, LLC, Cause No. 2015DCV-2205, currently pending in the 319th Judicial
District Court, Nueces County, in Corpus Christi. This case required Mr.
MacVane to travel to Corpus Christi last week in preparation for a temporary
injunction hearing held July 23, 2015. Mr. MacVane spent much of the last month
preparing witnesses and materials for the temporary injunction hearing, which
was not anticipated when Mr. Washington filed his initial request for an
extension.
3. In order to adequately focus on the briefing in this case, Mr.
Washington requests a 14-day extension of the deadline for his appellant’s brief.
A 14-day extension of the briefing deadline would make appellants’ brief due on
Monday, August 17, 2015.
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Request for Relief
For the above reasons, Craig A. Washington asks this Court to extend for
14 days the deadline for the filing of his principal brief in this appeal, making the
new deadline August 17, 2015.
Respectfully submitted,
/s/ John MacVane Gardere Wynne Sewell LLP
Michael A. Stafford 1000 Louisiana, Suite 2000
Texas Bar No. 18996970 Houston, Texas 77002-5007
Katharine David Tel: 713.276.5500
Texas Bar No. 24045749 Fax: 713.276.5555
John MacVane mstafford@gardere.com
Texas Bar No. 24085444 kdavid@gardere.com
jmacvane@gardere.com
ATTORNEYS FOR
CRAIG A. WASHINGTON, APPELLANT
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CERTIFICATE OF SERVICE
I certify that a copy of this document was served on July 29, 2015, by
delivery to the following counsel via the Electronic Filing Manager:
Cynthia Canfield Hamilton
Office of the Chief Disciplinary
Counsel
State Bar of Texas
Post Office Box 12487
Austin, Texas 78711
chamilton@texasbar.com
/s/ John MacVane
John MacVane
Certificate of Conference
The parties’ counsel have conferred regarding the relief requested in this
motion. Counsel for the appellee—Commission for Lawyer Discipline—
indicated that it will not oppose this request for relief.
/s/ John MacVane
John MacVane
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