- ACCEPTED 05-15-00278-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 11/9/2015 11:35:45 AM LISA MATZ CLERK NO. 05-15-00278-CV _______________________________________________________ FILED IN 5th COURT OF APPEALS IN THE FIFTH DISTRICT COURT OF APPEALS DALLAS, TEXAS DALLAS, TEXAS 11/9/2015 11:35:45 AM _______________________________________________________ LISA MATZ Clerk Julie Schmader, Appellant, v. Matthew Butschek d/b/a Accen Financial Services, Appellees. _______________________________________________________ APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF _______________________________________________________ TO THE HONORABLE COURT OF APPEALS: 1. Appellees’ Brief is due on November 10, 2015. 2. This Court previously granted two extensions to Appellant and two extensions to Appellees. 3. The undersigned apologizes for the need to request a third extension, but the circumstances are exceptional. The undersigned has, over the past six weeks, experienced the heaviest workload in his 24 years of practice. MOTION FOR EXTENSION PAGE 1 4. In the past week alone, the undersigned argued a complex and important home school education case in the Supreme Court of Texas, and State of Texas v. Al Hill III in the Texas Court of Criminal Appeals. These arguments followed another oral argument in the Supreme Court of Texas just three weeks ago. Upon concluding the Hill argument, counsel immediately had to file an appellant’s brief in the Fort Worth Court of Appeals, and has a petition for review due in the Supreme Court of Texas on Thursday, November 12, 2015. He then has oral argument in this Court on November 17, 2015. 5. Appellees seek an 21-day extension to make their brief due on November 30, 2015. They do not intend to seek any further extension. 6. Counsel for appellant does not oppose this motion. Based on the foregoing, appellees ask that the deadline for their brief be extended to November 30, 2015. MOTION FOR EXTENSION PAGE 2 Respectfully submitted, /s/Charles “Chad” Baruch Texas Bar Number 01864300 Johnston Tobey Baruch, PC 3308 Oak Grove Avenue Dallas, Texas 75204 Telephone: (214) 741-6260 Facsimile: (214) 741-6248 E-Mail: chad@jtlaw.com Attorney for Appellees CERTIFICATE OF CONFERENCE The undersigned certifies that he conferred with Thomas Cowart, who stated in writing that he does not oppose the relief sought by this motion. /s/Charles “Chad” Baruch CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of this instrument was served upon all counsel of record by e-filing upon Thomas Cowart on November 9, 2015. /s/Charles “Chad” Baruch MOTION FOR EXTENSION PAGE 3
Document Info
Docket Number: 05-15-00278-CV
Filed Date: 11/9/2015
Precedential Status: Precedential
Modified Date: 9/29/2016