Raul Martinez v. Deutsche Bank National Trust Company as Trustee for Ameriquest Mortgage Securities, Inc. Asset-Backed Pass-Through Certificates Series 2003-6 Homeward Residential, Inc. And Juanita Strickland

ACCEPTED
03-14-00721-CV
3773801
THIRD COURT OF APPEALS
AUSTIN, TEXAS
January 14, 2015 1/14/2015 4:57:51 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00721-CV

In The Third
Court of Appeals
Austin Division

Raul Martinez,
Appellant,

v.

Deutsche Bank National Trust Company as Trustee for Amiquest Mortgage Securities,
Inc.; Asset-Backed Pass-Through Certificates Series 2003-6; Homeward Residential, Inc.;
and Juanita Strickland,
Appellee.

ON APPEAL FROM THE DISTRICT COURT, 201ST JUDICIAL DISTRICT, TRAVIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. D-1-GN-13-001195

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT’S BRIEF

WILLIAM B. GAMMON, SBN: 07611280
GAMMON LAW OFFICE, PLLC.
1201 Spyglass Drive, Suite 100
Austin, Texas 78746
Phone: 512-444-4529
Fax: 512-545-4279
Firm@GammonLawOffice.com
ATTORNEY FOR APPELLANT

MOTION TO EXTEND APPELLANT’S BRIEF DEADLINE
CAUSE NO. 03-14-00721-CV
PAGE 1 OF 3
TO THE HONORABLE THIRD COURT OF APPEALS

COMES NOW, Raul Martinez, by and through his attorneys of record and files this

Unopposed Motion for Extension of time to file Appellant’s Brief. In support thereof, Appellant

will show as follows:

1. Appellant’s brief is currently due on January 19, 2015.

2. Appellant wishes to extend the current deadline for Appellant’s Brief by 30 days.

3. Appellant does not seek this extension for purposes of delay, but so counsel may facilitate

the most efficient and effective contention, by utilizing all available resources in order to

provide effective representation.

4. Appellant has conferred with Appellee regarding the relief sought herein and Appellee has

advised that Appellee is unopposed with the relief sought in said motion.

WHEREFORE PREMISES CONSIDERED, Appellant respectfully requests the court

extend the time period from January 19, 2014, to February 18, 2014 in which to file Appellant’s

brief.

Respectfully submitted,

/s/ Karla Huertas
By: _________________________________
KARLA HUERTAS, SBN: 24087765
WILLIAM B. GAMMON, SBN: 07611280
GAMMON LAW OFFICE, PLLC.
1201 Spyglass Drive, Suite 100
Austin, Texas 78746
Phone: 512-444-4529
Fax: 512-545-4279
Firm@GammonLawOffice.com
Counsel for Appellant

MOTION TO EXTEND APPELLANT’S BRIEF DEADLINE
CAUSE NO. 03-14-00721-CV
PAGE 2 OF 3
 CERTIFICATE OF CONFERENCE

Pursuant to Texas Rules of Appellate Procedure 10.1(a)(5), I hereby certify that our office has
conferred, or made a reasonable attempt to confer, with all other parties which are listed below
about the merits of this motion on the 14th day of January, 2015.

Jeremy Overbey: Attorney for Appellee
Date Contacted: January 14, 2015
Method of contact: Email
Results: Attorney for Appellee has advised that they are unopposed to the relief sought herein.

/s/ Karla Huertas
_____________________________
Karla Huertas

CERTIFICATE OF SERVICE

Pursuant to Texas Rules of Appellate Procedure 9.5, I hereby certify that a true and correct copy
of the foregoing instrument has been served on this 14th day of January, 2015.

Participants in the case who are registered ProDoc users will be served by the ProDoc system and
copies will be mailed via facsimile to those indicated as non-registered participants on January
14th, 2015.

JEREMY J. OVERBEY, SBN: 24046570
SETTLEPOU
3333 Lee Parkway, Eighth Floor
Dallas, Texas 75219
Phone: 214-520-3300
Fax: 214-526-4145
joverbey@settlepou.com
Counsel for Appellee

/s/ Karla Huertas
_____________________________
Karla Huertas

MOTION TO EXTEND APPELLANT’S BRIEF DEADLINE
CAUSE NO. 03-14-00721-CV
PAGE 3 OF 3