in the Matter of the Estate of Ruby Renee Byrom ( 2015 )

ACCEPTED
12-15-00033-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
6/15/2015 1:38:00 PM
CATHY LUSK
CLERK
IN THE COURT OF APPEALS
FOR THE TWELFTH APPELLATE DISTRICT OF TEXAS
FILED IN
12th COURT OF APPEALS
TYLER, TEXAS TYLER, TEXAS
6/15/2015 1:38:00 PM
CATHY S. LUSK
§ Clerk
§
IN THE MATTER OF THE ESTATE §
OFRUBYRENEEBYROM § CAUSE NUMBER 12-15-00033-CV
§
§
§
FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF
NOW COMES JILL CAMPBELL PENN in the above styled and numbered cause, and
files this motion for the Court to extend the time for filing of the Appellee's Brief pursuant to the
Texas Rules of Appellate Procedure and for good cause shows the following:
I.
The Appellee's Brief is currently due in the Court of Appeals on June 17, 2015. Appellant's
Briefwas filed on May 18, 2015.
II.
Appellee seeks an extension of time until July 17, 2015, to file Appellee's Brief. There
have been no previous extensions of time requested or granted with regard to the filing of
Appellee's Brief.
III.
It has not been possible for Counsel to complete the brief due to a busy court schedule,
including preparation for a hearing in Cause No. 2009-31036-211; a civil commitment hearing in
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Cause No. F-2013-1515-C; seeking emergency reliefin Cause No. 15-04677-431 and preparing
for hearing in that cause and companion Cause No. 15-03526-442. In addition, Counsel is
preparing to file for emergency relief in three other family law cases.
This motion is made in good faith and is not a dilatory tactic.
WHEREFORE, PREMISES CONSIDERED, Jill Campbell Penn prays that the Court
grant the Motion for Extension of Time to File Appellee's Brief, and that the deadline for filing
the briefbe extended until July 17, 2015.
Respectfully submitted,
Joseph F. Zellmer
State Bar Number 22258515
620 West Hickory Street
Denton, Texas 76201
Telephone: 94 3-2674
Facsimile: 4 I 82-7174
I verify that the facts stated above are true.
SUBSCRIBED AND SWORN TO BEFORE ME, on this the \)~of ~ ,
2015, to certify which witness my hand and seal of office.
Notary Public, State of Texas
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CERTIFICATE OF CONFERENCE
This is to certify that I left a message for Appellant's Counsel Joe Shumate on June 15,
2015, in regard to the First Motion for Extension of Time to File Appellee's Brief, and at the
time of filing have not received a response from Mr. Shumate.
Joseph F.
CERTIFICATE OF SERVICE
I hereby certify that on this the 151h day of June, 2015, a true and correct copy of the
above and foregoing First Motion for Extension of Time to File Appellee's Brief was served on
Joe Shumate, by eservice.
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