ACCEPTED 06-15-00017-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/26/2015 3:08:41 PM DEBBIE AUTREY CLERK No. 06-15-00017-CV IN THE COURT OF APPEALS FOR THE FILED IN 6th COURT OF APPEALS SIXTH DISTRICT OF TEXAS TEXARKANA, TEXAS AT TEXARKANA 6/26/2015 3:08:41 PM DEBBIE AUTREY Clerk BILLY FITTS and FREIDA FITTS, Appellants, v. MELISSA RICHARDS-SMITH, THE LAW FIRM OF GILLAM & SMITH, LLP, E. TODD TRACY, and THE TRACY FIRM, Attorneys at Law, Appellees. On Appeal from the 71st District Court of Harrison County, Texas Trial Court Cause No. 14-0150 UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLEES TO THE HONORABLE COURT OF APPEALS: Melissa Richards-Smith and the Law Firm of Gillam & Smith, LLP (Appellees) file this Unopposed Motion for Extension of Time to File Appellees’ Brief and would respectfully show: Appellants filed their brief on June 8, 2015, making Appellees’ brief due on July 8, 2015. See Tex. R. App. P. 38.6(b). Appellees wish to extend that deadline by thirty days, or until August 7, 2015. See Tex. R. App. P. 38.6(b). This is Appellees’ first request for an extension of time to file its Appellees’ Brief. This extension of time is necessary because the attorney primarily responsible for drafting the brief, Wade Crosnoe, will be on a previously scheduled vacation on the current filing deadline and the preceding holiday weekend. Additionally, Mr. Crosnoe’s work on other cases will prevent him from preparing the brief by the current deadline, including (1) drafting of post-submission briefing invited by the Court in an appeal styled Allstate Insurance Co., et al. v. Michael Kent Plambeck, D.C., et al., No. 14-10574, in the United States Court of Appeals for the Fifth Circuit; and (2) work on various responses and replies in connection with a motion to compel discovery and a motion to strike objections, and attendance at the June 16, 2015 hearing on those motions, in a case styled Munif Ali Gattas Bultaif, et al. v. Bridgestone/Firestone, Inc., et al., Cause No. 04-6262- J, in the 191st District Court of Dallas County, Texas. Appellants Billy Fitts and Freida Fitts are not opposed to this motion. Appellees E. Todd Tracy and the Tracy Firm are also unopposed. For these reasons, Appellees respectfully request that the Court grant this motion and extend the deadline to file its Brief until August 7, 2015. Appellees also request all other relief to which it is justly entitled. 2 Respectfully submitted, THOMPSON, COE, COUSINS & IRONS L.L.P. By: /s/ Wade Crosnoe Wade C. Crosnoe State Bar No. 00783903 701 Brazos, Suite 1500 Austin, TX 78701 Telephone: (512) 703-5078 Fax: (512) 708-8777 E-mail: wcrosnoe@thompsoncoe.com Shawn W. Phelan State Bar No. 00784758 Plaza of the Americas 700 N. Pearl Street, Twenty-Fifth Floor Dallas, TX 75201-2832 Telephone: (214) 871-8245 Telecopy: (214) 871-8209 E-Mail: sphelan@thompsoncoe.com Attorneys for Appellees Melissa Richards- Smith and Law Firm of Gillam & Smith, LLP 3 CERTIFICATE OF SERVICE I certify that a true and correct copy of this Unopposed Motion for Extension of Time to File Brief of Appellees was served on June 26, 2015, via electronic service or email, to the following counsel: Lindsey M. Rames Rames Law Firm, P.C. 5661 Mariner Drive Dallas, TX 75237 Telephone: 214.884.8860 Facsimile: 888.482.8894 Email: lindsey@rameslawfirm.com Carter L. Hampton Hampton & Associates, P.C. 1000 Houston Street, Fourth Floor Fort Worth, TX 76102 Telephone: 817.877.4202 Facsimile: 817.877.4204 Email: clhampton@hamptonlawonline.com Attorneys for Appellants, Billy Fitts and Freida Fitts Bruce A. Campbell Campbell & Chadwick 4201 Spring Valley Road, Suite 1250 Dallas, TX 75244 Attorney for Appellees E. Todd Tracy and The Tracy Firm, Attorneys at Law /s/ Wade C. Crosnoe Wade C. Crosnoe 4