Craig A. Washington v. Commission for Lawyer Discipline ( 2015 )

ACCEPTED
03-15-00083-CV
6760110
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/2/2015 11:07:19 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00083-CV
_______________
FILED IN
3rd COURT OF APPEALS
In the Court of Appeals AUSTIN, TEXAS
Third District of Texas 9/2/2015 11:07:19 AM
JEFFREY D. KYLE
Austin, Texas Clerk
_______________
CRAIG A. WASHINGTON,
APPELLANT
V.
COMMISSION FOR LAWYER DISCIPLINE,
APPELLEE
_______________
Appealed from the 335th District Court
Of Bastrop County, Texas
Honorable George Gallagher, Judge Presiding
_______________
APPELLEE’S UNOPPOSED FIRST MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
_______________
LINDA A. ACEVEDO CYNTHIA CANFIELD HAMILTON
CHIEF DISCIPLINARY COUNSEL SENIOR APPELLATE COUNSEL
LAURA BAYOUTH POPPS OFFICE OF THE CHIEF DISCIPLINARY
DEPUTY COUNSEL FOR ADMINISTRATION COUNSEL
STATE BAR OF TEXAS
P.O. BOX 12487
AUSTIN, TEXAS 78711-2487
512.427.1350; 1.877.953.5535
FAX: 512.427.4167
No. 03-15-00083-CV
_______________
In the Court of Appeals
Third District of Texas
Austin, Texas
_______________
CRAIG A. WASHINGTON,
APPELLANT
V.
COMMISSION FOR LAWYER DISCIPLINE,
APPELLEE
_______________
Appealed from the 335th District Court
Of Bastrop County, Texas
Honorable George Gallagher, Judge Presiding
_______________
APPELLEE’S UNOPPOSED FIRST MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
_______________
Appellee, the Commission for Lawyer Discipline, asks the Court, pursuant
to Rule 38.6(d) of the Texas Rules of Appellate Procedure, for an extension of time
of thirty (30) days to file Appellee’s brief.
I.
This is an appeal from a Final Judgment entered on January 8, 2015, against
Appellant, Craig A. Washington, in Cause No. 29,123, styled Commission for
Lawyer Discipline v. Craig A. Washington, in the 335th Judicial District Court of
Bastrop County, Texas.
II.
Appellant timely perfected his appeal. The clerk’s record was filed on May
8, 2015, and supplemental clerk’s records were filed on June 2, 2015 and July 9,
2015. The reporter’s record was filed on May 15, 2015. Appellant filed his brief
on August 17, 2015.
III.
This is Appellee's first request for an extension of time to file its brief.
Appellee’s brief is originally due to be filed on September 16, 2015. Appellee
requests an additional thirty (30) days to file the brief, to and including October
16, 2015. Appellee’s counsel, the undersigned attorney, needs additional time to
file the brief for the following reasons:
The undersigned has been out of the office unexpectedly due to the
emergency surgery and hospitalization of her mother, for whom the
undersigned is the primary caretaker;
The undersigned will be out of the office at a conference from September 9-
11, 2015;
The undersigned is set to present oral argument on September 16, 2015, in
John Doe v. Board of Directors of the State Bar of Texas, et al, before the
Third Court of Appeals (No. 03-15-00007-CV); and
The undersigned has a previously extended briefing deadline of September
28, 2015, in Charles Septowski v. Commission for Lawyer Discipline, before
the Board of Disciplinary Appeals (BODA No. 55901).
IV.
For these reasons, Appellee prays that this Court grant Appellee’s motion in
this cause for thirty (30) days until October 16, 2015.
RESPECTFULLY SUBMITTED:
LINDA A. ACEVEDO
CHIEF DISCIPLINARY COUNSEL
LAURA BAYOUTH POPPS
DEPUTY COUNSEL FOR ADMINISTRATION
CYNTHIA CANFIELD HAMILTON
SENIOR APPELLATE COUNSEL
OFFICE OF THE CHIEF DISCIPLINARY
COUNSEL
P.O. BOX 12487
AUSTIN, TEXAS 78711-2487
512.427.1350; 1.877.953.5535
FAX: 512.427.4167
/s/ Cynthia Canfield Hamilton
CYNTHIA CANFIELD HAMILTON
SENIOR APPELLATE COUNSEL
STATE BAR OF TEXAS
cynthia.hamilton@texasbar.com
STATE BAR CARD NO. 00790419
ATTORNEYS FOR APPELLEE
CERTIFICATE OF CONFERENCE
This is to certify that Appellant’s attorney, Mr. John MacVane, indicated that
Appellant does not oppose the requested extension.
/s/ Cynthia Canfield Hamilton
CYNTHIA CANFIELD HAMILTON
CERTIFICATE OF SERVICE
This is to certify that the foregoing Unopposed First Motion for Extension of Time
to File Brief has been served on Appellant, Mr. Craig A. Washington, by and
through his attorneys of record Mr. Michael A. Stafford, Ms. Katherine David, and
Mr. John MacVane, Gardere, Wynne Sewell LLP, 1000 Louisiana, Suite 3400,
Houston, Texas 77002-5011, through this Court’s electronic filing service provider
on the 2nd day of September 2015.
/s/ Cynthia Canfield Hamilton
CYNTHIA CANFIELD HAMILTON