ACCEPTED
03-14-00658-CV
3634773
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/2/2015 10:56:48 AM
JEFFREY D. KYLE
CLERK
NO. 03-14-00658-CV FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
1/2/2015 10:56:48 AM
JEFFREY D. KYLE
In The Clerk
Third Court of Appeals
____________________________________________________________________
ROBYN N. JONES,
Appellant,
v.
WELLS FARGO BANK, N.A.,
Appellee.
____________________________________________________________________
Cause No. 11-0479
On Appeal from the 428th District Court, Hays County, Texas
Honorable Bill Henry, Judge Presiding
____________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF
____________________________________________________________________
TO THE HONORABLE THIRD COURT OF APPEALS:
Pursuant to Rules 10.5(b) and 38.6(d), TEX. R. APP. P., Appellee Wells
Fargo Bank, N.A. respectfully moves this Court to extend the time for filing its
Appellee’s Brief by 30 days to February 10, 2015.
1. Background: Appellant’s Brief was filed on December 12, 2014.
Appellee’s Brief is therefore due on January 11, 2015.
2. Grounds for the extension: Due to the Christmas holidays, Appellee’s
counsel’s travel plans, and a number of other engagements, Appellee’s counsel
needs an additional 30 days to prepare Appellee’s brief.
3. Unopposed: Counsel for Appellant has stated that Appellant does not
oppose this Motion.
4. Number of extensions: This is Appellee’s first request for an
extension of time for the filing of its Appellee’s Brief.
PRAYER
Appellee prays that this Motion be granted and that the time for filing its
Appellee’s Brief be extended by 30 days to February 10, 2015. Appellee also
prays for such other and further relief to which it may be entitled at law or in
equity.
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Respectfully submitted,
LOCKE LORD LLP
By: /s/ Ryan D. V. Greene
B. David L. Foster
dfoster@lockelord.com
State Bar No. 24031555
Ryan D. V. Greene
rgreene@lockelord.com
State Bar No. 24012730
600 Congress Avenue, Suite 2200
Austin, Texas 78701
Telephone: (512) 305-4700
Facsimile: (512) 305-4800
W. Scott Hastings
shastings@lockelord.com
State Bar No. 24002241
Robert T. Mowrey
rmowrey@lockelord.com
State Bar No. 14607500
2200 Ross Avenue, Suite 2200
Dallas, Texas 75201
Telephone: (214) 740-8000
Facsimile: (214) 740-8800
Counsel for Appellee Wells Fargo Bank, N.A.
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CERTIFICATE OF CONFERENCE
I hereby certify that counsel for Appellee, Ryan D. V. Greene,
communicated on December 23, 2014 by email with Doug W. Ray (counsel for
Appellant), and that Mr. Ray has informed Mr. Greene that this motion is
unopposed.
/s/ Ryan D. V. Greene
Ryan D. V. Greene
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served on the
following counsel of record by the CM/ECF system or, if any counsel is not
registered, by United States mail on this the 2nd day of January, 2015:
Doug W. Ray
Ray & Wood
2700 Bee Caves Road
Austin, Texas 78746
/s/ Ryan D. V. Greene
Ryan D. V. Greene
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