ACCEPTED
03-14-00341-CV
3653153
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/5/2015 3:24:56 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00341-CV
FILED IN
In the Third Court of Appeals 3rd COURT OF APPEALS
AUSTIN, TEXAS
1/5/2015 3:24:56 PM
JEFFREY D. KYLE
James Richardson Clerk
Appellant,
v.
Maria Torres, et al.
Appellees
Appeal from Cause No. C-1-CV-13-009448
County Court No. 2, Travis County, Texas
Hon. David Phillips
APPELLANT’S MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
KING LAW GROUP, P.L.L.C.
Mary Ellen King
Texas State Bar No. 24067219
meking@kinglitigationgroup.com
Richard C. King Jr.
Texas State Bar No. 24007491
rking@kinglitigationgroup.com
28515 Ranch Road 12
Dripping Springs, Texas 78620
512.263.8212 (phone)
512.900.2918 (fax)
Counsel for Appellant, James Richardson
Comes now Appellant James Richardson, pursuant to Texas Rules of Civil
Procedure 10.5(b)(1), and requests additional time to file his Appellant’s Reply
Brief. In support of this motion, Richardson states as follows:
1. The Notice of Appeal of this matter was filed in the 3rd Court of Appeals
(the “Court”) on May 28, 2014;
2. Appellant filed the Docketing Statement with the Court on June 6, 2014;
3. Appellant immediately requested the Reporter’s Record and the Clerk’s
Record from County Court No. 2 in Travis County, Texas.
4. The Reporter’s Record, and the Supplemental Reporter’s Record, were
filed with the Court on June 11, 2014, and June 18, 2014, respectively.
5. The Clerk’s Record was filed with the Court on June 24, 2014.
6. The Supplemental Clerk’s Record was filed September 2, 2014.
7. The Appellant filed its brief on September 26, 2014.
8. The Appellee filed its brief on December 18, 2014.
9. The due date of Appellant’s Reply Brief is January 7, 2015, which is the
current deadline for the filing of that brief, and for which the Appellant
seeks this extension;
10.Appellant requests an extension to file Appellant’s Reply Brief, up to and
including January 23, 2015;
11.The requested extension is unopposed;
12.In support of this Motion, Appellant states that the additional time is
sought for the purpose of allowing counsel adequate time to prepare the
brief; further, that Appellant counsel’s office is a small law office with an
active litigation and trial practice, and that the prior obligations of
counsel to trial, discovery and other matters, as well as previously-
planned vacations and the extension of time granted to Appellee’s
counsel for the filing of the appellee brief, necessitate the additional time
requested herein; and, further, that the extension requested herein is not
intended to cause undue delay, prejudice or unnecessary hardship on any
party; and,
13.Appellant has not requested, and has not been granted, any previous
extensions of time for the filing of his Appellant’s Reply Brief.
WHEREFORE, Appellant requests an extension up to and including January
23, 2015, to file Appellant’s Reply Brief.
Dated this 5th day of January 2015.
Respectfully submitted,
KING LAW GROUP, PLLC
/s/ Richard C. King Jr.
Mary Ellen King
Texas State Bar No. 24067219
meking@kinglitigationgroup.com
Richard C. King Jr.
Texas State Bar No. 24007491
rking@kinglitigationgroup.com
28515 Ranch Road 12
Dripping Springs, Texas 78620
512.263.8212 (phone)
512.900.2918 (fax)
Attorneys for Appellant James
Richardson
CERTIFICATE OF CONFERENCE
Counsel for Appellant hereby represents to the Court that he conferred with
Appellee’s counsel via telephone on December 28, 2014 and again on January 5,
2015, regarding the extension requested in this motion, and counsel for Appellee
agreed with and consented to such extension.
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the following instrument
has been served to opposing counsel via facsimile on this the 5th day of January,
2015.
Jesus Tirrez
THE LAW OFFICE OF JESUS TIRREZ & ASSOCIATES
1301 South IH-35, Suite 307
Austin, Texas 78741
Attorneys for Appellees Maria Torres, et al.
/s/ Richard C. King Jr.
Richard C. King Jr.