ACCEPTED
06-14-00104-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
2/9/2015 12:27:30 PM
DEBBIE AUTREY
CLERK
06-14-00104-CV
FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
IN T H E S I X T H C O U R T O F A P PE AL2/9/2015
S 12:27:30 PM
T E X AR K AN A, TE X AS DEBBIE AUTREY
Clerk
REEF R. GILLUM, D.O., ET AL.,
APPELLANTS,
V.
GREG A. GILLUM,
APPELLEE.
Un op p osed Mot ion F or Exten s ion
O f T ime T o F ile Ap pe llant s ’ Br ief
I.
Appellants’ opening brief is due on February 9, 2015. Appellants request
that the Court grant them a 30-day extension of time, until March 11, 2015,
to file their brief. This is Appellants’ first request for an extension of time to
file this brief and is unopposed.
II.
Appellants need additional time because it has been and will be
necessary for appellate counsel Robert B. Gilbreath and Matthew C. Sapp to
devote their time to a number of other matters, including:
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• Preparation of a motion for rehearing in Case No. 14-0543,
pending in the Texas Supreme Court.
• Preparation of a motion for summary judgment and Daubert
motion in Cause No. 2:13-CV-00945, pending in the United
States District Court for the District of New Mexico.
• Preparation for oral argument in Cause No. 05-13-01765-CV,
pending before the Fifth Court of Appeals (scheduled for
February 18, 2015).
• Preparation of a motion to intervene and third-party complaint
on behalf of intervenors in Cause No. 2:13-CV-02391, pending
in the United States District Court for the Eastern District of
Pennsylvania.
PRAYER
Appellants request that the Court grant them a 30-day extension of time
to file their brief and award them any other relief to which they are entitled.
Respectfully submitted,
/s/ Robert B. Gilbreath
Robert B. Gilbreath
Texas State Bar No. 07904620
Matthew C. Sapp
Texas State Bar No. 24063563
HAWKINS PARNELL
THACKSTON & YOUNG, LLP
Highland Park Place
4514 Cole Avenue, Suite 500
Dallas, Texas 75205
Telephone: (214) 780-5100
Facsimile: (214) 780-5200
COUNSEL FOR APPELLANTS
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CERTIFICATE OF CONFERENCE
I spoke with Jim Bullock, counsel for Greg Gillum, regarding this
motion. He stated that his client does not oppose this motion.
/s/ Robert B. Gilbreath
Robert B. Gilbreath
C ERT IFI CAT E OF S ERV IC E
On February 9, 2015, a true and correct copy of this notice was sent via
e-mail and certified mail to the following counsel of record:
Jim E. Bullock, Esq.
Brian Casper, Esq.
Cantey Hanger, LLP
19999 Bryan Street, Suite 3300
Dallas, Texas 75201
jbullock@canteyhanger.com
bcasper@canteyhanger.com
/s/ Robert B. Gilbreath
Robert B. Gilbreath
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