Inez Manigault v. Jane Thorn-Henderson ( 2015 )


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  •                                                                                                            ACCEPTED
    12-14-00156-CV
    TWELFTH COURT OF APPEALS
    TYLER, TEXAS
    7/6/2015 1:48:06 PM
    CATHY LUSK
    CLERK
    UNITED STATES TWELFTH COURT OF APPEALS                         FILED IN
    12th COURT OF APPEALS
    TYLER, TEXAS
    INEZ MANIGAULT,                              §
    7/6/2015 1:48:06 PM
    Plaintiff,                              §
    §                                  CATHY S. LUSK
    Clerk
    Vs.                                          §       Case No. 12-14-00156-CV
    §
    JANE THORN-HENDERSON                         §
    APPELLEE’S FIRST MOTION FOR EXTENSION
    OF TIME TO FILE BRIEF
    TO THE HONORABLE JUSTICES OF THIS COURT:
    Jane Thorne-Henderson requests an order extending time to file her brief as follows:
    Appellee requests a one week extension of time to file her brief because counsel for
    appellee was originally scheduled to attend trial of Cause No: DC-13-07008, styled Maria
    Alonzo v. Linda Meredith, in the 191st District Court of Dallas County, Texas; and then the day
    after, on Tuesday, June 7, 2015, was scheduled to begin an arbitration proceeding with the
    American Arbitration Association styled Mike Pile BMW v. Lay Construction, LLC, Cause No.
    01-14-0001-7427. Both those matters resolved during the afternoon of Thursday July 3, 2015.
    Because of these other matters, counsel was unable to complete his client’s response by the
    deadline, today.
    Appellee’s brief in the in this matter is due today, July 6, 2015. By this motion, appellee
    requests an order extending the time to file appellee’s brief to Monday, July 13, 2015.
    Appellee has requested no previous extension of time in this appellate cause. Counsel for
    appellee requires additional time in which to file this brief because of the following
    circumstances described supra.
    No party will be prejudiced by the extension requested herein.
    1
    Conference
    Counsel attempted to confer with pro se Appellant on July 6, 2015, and Appellant
    counsel did not respond at all. Counsel has therefore received no agreement or opposition to
    this motion.
    Prayer for Relief
    Therefore, appellee respectfully requests that this Court issue an order granting the
    extension the time for the filing of the appellant’s brief in the above case to Monday July 13,
    2015.
    Respectfully submitted,
    WHITE SHAVER, P.C.
    205 W. Locust Ave.
    Tyler, Texas 75702
    Telephone: 903/533-9447
    Telefax: 903/595-3766
    By:
    Adam B. Allen
    State Bar No. 24038738
    AAllen@whiteshaverlaw.com
    ATTORNEY FOR APPELLEE
    CERTIFICATE OF SERVICE
    I do certify that a true and correct copy of the foregoing Response was delivered to all
    counsel and parties of record, via mail in accordance with the Texas Rules of Civil Procedure on
    this 6TH day of July, 2015.
    _________________________________
    Adam B. Allen
    2
    CERTIFICATE OF CONFERENCE
    I hereby certify that on July 6, 2015, I attempted to confer with pro-se appellant regarding
    the motion for extension of time, and appellant did not respond.
    ________________________________
    Adam Allen
    3
    

Document Info

Docket Number: 12-14-00156-CV

Filed Date: 7/6/2015

Precedential Status: Precedential

Modified Date: 9/29/2016