ACCEPTED
06-14-00099-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
4/13/2015 10:55:34 AM
DEBBIE AUTREY
CLERK
No. 06-14-00099-CV
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IN THE COURT OF APPEALS FILED IN
6th COURT OF APPEALS
FOR THE SIXTH DISTRICT OF TEXAS AT TEXARKANA
TEXARKANA, TEXAS
————————————————————————————————— 4/13/2015 10:55:34 AM
RICHARD PARKER DEBBIE AUTREY
Clerk
Appellant
v.
JOANN PARKER NEAL
Appellee
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On Appeal from the 276th District Court of Camp County
Robert Rolston, Judge Presiding
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UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEE’S BRIEF
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Appellee JoAnn Parker Neal moves for an unopposed extension of time to file
her Appellee’s brief in this proceeding and states the following in support:
I.
Appellee’s brief is due to be filed on April 24, 2015. Appellee respectfully
requests a thirty-day extension of time, until May 24, 2015, to file her brief. Appellee
is not filing this motion for the purpose of delay, but in the interest of justice.
UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEE’S BRIEF Page 1
II.
Appellant Richard Parker requested and was granted two unopposed extensions
of time to file his Appellant’s brief.
III.
Appellee has been represented in this appeal by her trial counsel, Lance
Hinson. Appellee has now determined that it would be in her best interest to be
represented on appeal by an attorney who focuses his practice on appellate law. As
such, Appellee hired Chad Ruback to be her lead appellate counsel. Ruback is filing
his notice of appearance of counsel and designation of lead counsel
contemporaneously with this motion.
Ruback is busy preparing the following other appellate briefs:
(1) an appellant’s brief in LBSP, Inc. Forest Dale, Inc., 05-14-01295-CV in
the Dallas Court of Appeals, due on April 15, 2015; and
(2) an appellant’s reply brief in Meyer v. Meyer, 05-14-00655-CV in the
Dallas Court of Appeals, due on May 15, 2015.
Consequently, Ruback will be unable to complete Appellee’s brief in this case
by the April 24, 2015 deadline.
UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEE’S BRIEF Page 2
IV.
WHEREFORE, PREMISES CONSIDERED, Appellee JoAnn Parker Neal
prays that this Court enter an order granting her Unopposed Motion for Extension of
Time to File Appellee’s Brief and specifying that Appellee’s brief be filed on or
before May 24, 2015.
Respectfully submitted,
/s/ Chad M. Ruback
Chad M. Ruback
State Bar No. 90001244
The Ruback Law Firm
8117 Preston Road
Suite 300
Dallas, Texas 75225
(214) 522-4243
(214) 522-2191 facsimile
chad@appeal.pro
CERTIFICATE OF CONFERENCE
On April 13, 2015, I conferred with Tom S. McCorkle, counsel for Appellant
Richard Parker, and he is unopposed to the relief sought in this motion.
/s/ Chad M. Ruback
Chad M. Ruback
UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEE’S BRIEF Page 3
CERTIFICATE OF SERVICE
On April 13, 2015, I served a copy of this document to the following counsel
for Appellant Richard Parker:
Tom S. McCorkle
403 W. Tyler Street
Gilmer, Texas 75644
/s/ Chad M. Ruback
Chad M. Ruback
UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEE’S BRIEF Page 4