Henry S. Miller Brokerage, LLC v. Ruth Mae Sanders

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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 •••oo AT&T~ 3:44 PM v ~ *55% ;a l• ( dougkittelson@icloud.c... Contact iMessage Today 1:50 PM Monday is fine for an extension to fUe your brief Thanks. I'll so represent In certificate of conference Delivered EXHIBIT ... I -/i •' ·~, ,-\ ', ( ' , '' ,,,., Send """ 3 ~----~--------·----~----------------