Reef R. Gillum, D.O. v. Greg A. Gillum

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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: Page 1 • 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 Page 2 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 Page 3