Anna Marie Inman v. Equable Ascent Financial, LLC ( 2015 )

ACCEPTED 12-15-00220-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 11/2/2015 4:31:18 PM Pam Estes CLERK No. 12-15-00220-CV In the FILED IN 12th COURT OF APPEALS TYLER, TEXAS Twelfth Court of Appeals 11/2/2015 4:31:18 PM PAM ESTES Tyler, Texas Clerk ________________________________ ANNA MARIE INMAN, Appellant VS. EQUABLE ASCENT FINANCIAL, LLC, Appellee ________________________________ APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF COMES NOW Anna Marie Inman, Appellant herein, and moves this Court for an extension of time to file their brief under TRAP 38.6(d), and in support thereof would show the following: 1. Appellant’s brief is now due on November 2, 2015. 2. Appellant requests a 30-day extension of the deadline for filing her brief, or until December 2, 2015. 3. Appellant seeks this extension of time for several reasons. First, one of the attorneys working on the brief, Heather Keegan, has not been able to work on her assigned issue, because she has been busy dealing with several hearings and outreach events over the past 3 weeks. Second, while much of the brief assigned to the undersigned has been completed, more time is needed to finish some legal research and drafting on the one issue being handled by the undersigned. 4. No previous extension of time to file a brief has been accorded by this Court to Appellant. Counsel for Appellee Equable Ascent Financial, LLC has informed counsel for Appellant that this motion is not opposed. WHEREFORE, Appellants prays that this Honorable Court grant this motion and extend the time for filing Appellant’s brief until January 30, 2015, and for such other and further relief to which they may be entitled. Respectfully submitted, LONE STAR LEGAL AID By: /s/ Richard Tomlinson RICHARD TOMLINSON 1415 Fannin Houston, Texas 77002 713/652-0077, ext. 1154 Fax: 713/652-3814 State Bar No. 20123500 ATTORNEY FOR APPELLANT Appellant’s Unopposed Motion for Extension of Time to File Brief Page 2 CERTIFICATE OF CONFERENCE On November 2, 2015 pursuant to TRAP 10.1(a)(5), counsel for Appellant sought to confer with counsel for Appellee, Dan G. Young of Jenkins, Wagnon & Young, P.C., about the merits of this motion and whether Appellee would oppose this motion. After leaving a message for Mr. Young and e-mailing him, he responded by e-mail that he would not oppose a 30-day extension of time for Appellant to file her brief. /s/ Richard Tomlinson Richard Tomlinson CERTIFICATE OF SERVICE Pursuant to T.R.A.P. 9.5, I hereby certify that I served a copy of the foregoing Appellant’s Unopposed Motion for Extension of Time by e-mail, fax, certified mail, return receipt requested, or by hand delivery, on this the 2nd day of November, 2015, as follows: Dan G. Young Jenkins, Wagnon & Young, P.C. P.O. Box 420 Lubbock, Texas 79408-0420 dgyservice@jwylaw.com ATTORNEY FOR APPELLEE /s/ Richard Tomlinson Richard Tomlinson Appellant’s Unopposed Motion for Extension of Time to File Brief Page 3