ACCEPTED
05-14-01618-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
1/29/2015 6:24:04 PM
LISA MATZ
CLERK
Cause No. 05-14-01618-CV
Henry S. Miller Brokerage, LLC § Court of Appeals FILED IN
§ 5th COURT OF APPEALS
Appellant (Plaintiff below) DALLAS, TEXAS
vs. § 5rn District of Texas
1/29/2015 6:24:04 PM
§
LISA MATZ
Ruth Mae Sanders § Clerk
Appellee (Defendant below) § Dallas, Texas
APPELLANT'S UNOPPOSED MOTION
FOR EXTENSION TO FILE BRIEF
1. Appellant's brief is due today, Thursday, January 29 1•
2. Appellant seeks a four-day extension to Monday, February 2.
3. The undersigned Jamie Wall is the attorney responsible for preparing Appellant's
brief. On Friday, January 23, Wall was retained as new counsel for a party in a pending lawsuit in
which depositions were scheduled for Monday and Tuesday, January 26 and 27. Case study,
preparation, and attendance at the depositions consumed much of the weekend and all of January 26-
27, which unexpectedly delayed Wall's commencement of Appellant's brief. Thereafter and during
the course of preparing the brief, Wall determined that additional legal research and analysis was
necessary, which further retarded progress on the brief.
4. The brief is underway, but will not be finished and ready to file by today's deadline.
Out of an abundance of caution, Appellant seeks to extend the deadline to Monday, February 2.
5. No previous extensions to file the brief have been granted
or requested.
6. Certificate of Conference: Appellee 's counsel is Douglas C, Kittelson. In response to
Wall's telephone voice message this afternoon to confer about this motion, Kittelson sent Wall a text
message expressing his non-opposition to the extension. See Exhibit A (copy of text message).
\
1
All dates referenced in this motion are in 2015 unless otherwise stated
Appellant's Unopposed Motion for Extension to File Brief Page 1
Wherefore, Appellant prays for an extension to Monday, February 2, 2015 to file Appellant's
brief.
Certificate of Service: On January 29, 2015, a true copy of this instrument was e-served on
Appellee's counsel through the Texas online filing system.
Respectfully submitted,
s/ Jamie Wall
Jamie Wall
Attorney at Law
State Bar No. 20756700
9551 Milltrail Drive
Dallas, Texas 75238
Telephone: 214-675-5534
jwall@sanijet.com
ACKERMAN & SAVAGE
Attorneys and Counselors
8226 Douglas Ave., Suite 330
Dallas, TX 75225
214-346-4200 (Telephone)
214-346-4201 (Facsimile)
W.RANDALLACKERMAN
State Bar No. 00832475
STEVEN T. RAMOS
State Bar No. 00784812
cyh(ij),ackennansavage.com
ATTORNEYS FOR APPELLANT
Appellant's Unopposed Motion for Extension to File Brief Page2
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Henry S. Miller Brokerage, LLC v. Ruth Mae Sanders
Combined Opinion