ACCEPTED
05-14-01394-cv
FIFTH COURT OF APPEALS
DALLAS, TEXAS
3/5/2015 10:56:01 AM
LISA MATZ
CLERK
NO. 051401394CV
IN THE COURT OF APPEALS
FOR THE FIFTH DISTRICT OF TEXAS FILED IN
5th COURT OF APPEALS
_________________________________________________________________
DALLAS, TEXAS
3/5/2015 10:56:01 AM
SUNNY LETOT, LISA MATZ
Clerk
Appellant
V.
UNITED SERVICES AUTOMOBILE ASSOCIATION,
Appellee
_________________________________________________________________
Appeal from the 1 92th Judicial District Court of Dallas County, Texas
Trial Court Cause No. 1300156B
_________________________________________________________________
APPELLANT’S UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
_________________________________________________________________
TO THE HONORABLE COURT OF APPEALS:
Appellant Sunny Letot (“Appellant”) files this Unopposed Motion for
Extension of Time to File Brief (the “Motion”), and in support thereof, would
show as follows:
I. DUE DATE
1. Appellant’s brief is currently due today, March 5, 2015.
2. Appellant seeks an additional seven (7) days to file its Brief until
Thursday, March 12, 2015.
II. REASON FOR EXTENSION OF TIME
3. Appellant’s requested extension is necessary because of the
inclement weather conditions in the Dallas metroplex, resulting in the closing of
counsel for Appellant’s offices. In addition, Appellant’s counsel has been
actively been engaged in other previouslyscheduled matters that have prevented
the timely completion of Appellant’s Brief.
4. These and other professional commitments have prevented the
timely completion of Appellant’s Brief, necessitating the requested extension of
seven (7) days to file Appellant’s Brief.
5. This is Appellant’s first request for a sevenday extension and the
request is unopposed.
III. EXTENSION SOUGHT IN THE INTEREST OF JUSTICE
6. Appellant’s Motion is not brought to cause undue delay but for good
cause and so that justice may be done.
IV. APPELLEE DOES NOT OPPOSE THIS MOTION
7. On March 5, 2015, counsel for Appellant conferred with counsel for
Appellee regarding the contents of this Motion, and counsel for Appellee stated
that he does not oppose this Motion.
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V. PRAYER FOR EXTENSION
For the reasons stated above, Appellant Sunny Letot respectfully requests
that this Unopposed Motion for Extension of Time to File Brief be granted, and
that the deadline to file Appellant’s Brief be extended by seven (7) days until
Thursday, March 12, 2015. Appellant further requests all such other relief to
which she may be justly entitled.
Date: March 5, 2015 Respectfully submitted,
/s/Jeffrey M. Tillotson
Jeffrey M. Tillotson
Texas Bar No. 20039200
jmt@lynnllp.com
LYNN TILLOTSON PINKER & COX, LLP
2100 Ross Avenue
Suite 2700
Dallas, Texas 75201
(214) 9813800
(214) 9813838 Facsimile
ATTORNEYS FOR APPELLANT
CERTIFICATE OF CONFERENCE
On March 5, 2015, I contacted Robert Owen, counsel for Appellee,
regarding the contents of this Motion, and Mr. Owen stated that he does not
oppose this Motion.
/s/Jeffrey M. Tillotson
Jeffrey M. Tillotson
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
FILE BRIEF was served upon the following counsel for the parties in accordance
with the Texas Rules of Appellate Procedure on March 5, 2015.
Robert T. Owen
Texas Bar No. 24060370
owen@rndjwlaw. corn
Levon G. Hovnatanian
Texas Bar No. 10059825
hovnatanian@mdjwlaw.com
MARTIN, DIsIERE, JEFFERSON & WISDOM L.L.P.
808 Travis, 20th Floor
Houston, Texas 77002
(713) 6321700 — Telephone
(713) 2220101 — Facsimile
/s/Jeffrey M. Tillotson
Jeffrey M. Tillotson
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