ACCEPTED 02-18-00139-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 5/24/2018 3:33 PM DEBRA SPISAK CLERK NO. 02-18-00139-CV IN THE COURT OF APPEALS FILED IN 2nd COURT OF APPEALS FOR THE SECOND DISTRICT OF TEXASFORT WORTH, TEXAS AT FORT WORTH 5/24/2018 3:33:56 PM DEBRA SPISAK Clerk JODY LONG, Appellant, v. AERONAUTICAL INDUSTRIAL DISTRICT LODGE 776; PAUL BLACK, In His Official Capacity As President- Directing Business Representative of District Lodge 776; and EARNEST BOONE, In His Official Capacity As Secretary-Treasurer of District Lodge 776, Appellees. Appeal from the 342nd Judicial District Court, Tarrant County, Texas Trial Court Cause No. 342-295833-17 The Honorable Dana Womack, Presiding AGREED MOTION TO EXTEND DEADLINE TO FILE APPELLANT’S BRIEF TO THE HONORABLE COURT OF APPEALS: Appellant Jody Long respectfully moves the Court to extend the time for filing Appellant’s Brief by 30 days, to and including July 2, 2018. Appellees do not oppose this requested extension. 1. The Appellant’s Brief is currently due on May 31, 2018. Agreed Motion to Extend Deadline to File Appellant’s Brief Page 1 2. Appellant requests a 30 day extension of time to file Appellant’s Brief, to and including July 2, 2018. See Tex. R. App. P. 4.1.(a). 3. Appellant is requesting this extension to allow the parties time to finalize a settlement agreement. A settlement has been reached in principle, and the parties are just working out the details of the settlement. 4. Appellant seeks this extension not solely for delay, but so that justice may be done. 5. As reflected in the Certificate of Conference below, Appellees are in agreement with the requested extension. Respectfully submitted, /s/ Lu Pham Lu Pham State Bar No. 15895430 lpham@dphllp.com Jennifer Bley Sweeny State Bar No. 24064910 jsweeny@dphllp.com DOWELL PHAM HARRISON, LLP 505 Pecan Street, Suite 200 Fort Worth, Texas 76102 817-632-6300 817-632-6311 – fax And Agreed Motion to Extend Deadline to File Appellant’s Brief Page 2 David E. Keltner State Bar No. 11249500 david.keltner@kellyhart.com Joe Greenhill State Bar No. 24084523 joe.greenhill@kellyhart.com KELLY HART & HALLMAN LLP 201 Main Street, Suite 2500 Fort Worth, Texas 76102 817-332-2500 817-878-9280 - fax ATTORNEYS FOR APPELLANT CERTIFICATE OF CONFERENCE I hereby certify that I conferred with counsel for Appellees, Rod Tanner, regarding the extension requested in this Motion. Mr. Tanner confirmed that Appellees agree to the relief requested in this Motion. /s/ Lu Pham Lu Pham CERTIFICATE OF SERVICE I hereby certify that on May 24, 2018, a copy of this Motion was served via e-filing on all counsel of record as follows: Rod Tanner rtanner@rodtannerlaw.com Charles Hairston chairston@rodtannerlaw.com TANNER AND ASSOCIATES, PC 6300 Ridglea Place, Suite 407 Fort Worth, TX 76116-5706 Attorneys for Appellees /s/ Lu Pham Lu Pham Agreed Motion to Extend Deadline to File Appellant’s Brief Page 3