Thomas D. Young A/K/A T. David Young v. JP Morgan Chase Bank, N.A. ( 2015 )

ACCEPTED 03-15-00261-CV 6310378 THIRD COURT OF APPEALS AUSTIN, TEXAS 7/31/2015 1:21:22 PM JEFFREY D. KYLE CLERK NO. 03-15-00261-CV FILED IN In the Third Court of Appeals 3rd COURT OF APPEALS AUSTIN, TEXAS 7/31/2015 1:21:22 PM Austin, Texas JEFFREY D. KYLE Clerk THOMAS D. YOUNG A/K/A T. DAVID YOUNG, APPELLANT v. JP MORGAN CHASE BANK, N.A., APPELLEE APPEAL FROM CAUSE NO. D-1-GN-12-000590 126TH DISTRICT COURT OF TRAVIS COUNTY, TEXAS HON. DARLENE BYRNE PRESIDING APPELLANT’S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF Stephen Casey Texas Bar No. 24065015 ORAL CASEY LAW OFFICE, P.C. ARGUMENT 595 Round Rock West Drive REQUESTED Suite 102 Round Rock, Texas 78681 Telephone: 512-257-1324 Fax: 512-853-4098 stephen@caseylawoffice.us Counsel for Appellant Thomas D. Young a/k/a T. David Young i GROUNDS FOR MOTION 1. Appellant’s Brief is due to be filed in Court on July 31, 2015. 2. Appellant’s counsel had a family crisis occur which resulted in Counsel needing to care for his 5 children. 3. Counsel will also be leaving for an out-of-town trip beginning August 1st through August 18th. Counsel is in need of more time to adequately draft and file Appellant’s Brief. 4. Appellant is asking for an extension until August 24, 2015. 5. This is Appellant’s second unopposed request for an extension. PRAYER For the foregoing reasons, Appellant prays the Court will grant the motion. Respectfully submitted, /s/ Stephen Casey Stephen Casey Texas Bar No. 24065015 595 Round Rock West Drive, Suite 102 Round Rock, Texas 78681 Telephone: 512-257-1324 Fax: 512-853-4098 stephen@caseylawoffice.us 1 CERTIFICATE OF CONFERENCE I hereby certify that I have conferenced with opposing counsel, Marcie L. Schout, via e-mail on July 31, 2015. Opposing counsel is unopposed to the Motion for Extension of Time to File Appellant’s Brief. /s/Stephen Casey CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing motion has been served on Friday, July 31, 2015, on the following via electronic transmission: Marcie L. Schout Quilling, Selander, Lownds, Winslett, & Moser, P.C. 2001 Bryan Street, Suite 1800 Dallas, TX 75201 mschout@qslwm.com /s/ Stephen Casey 2