ACCEPTED
03-14-00510-CV
4122911
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/12/2015 10:52:18 AM
JEFFREY D. KYLE
CLERK
No. 03-14-00510-CV
FILED IN
3rd COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
FOR THE THIRD COURT OF APPEALS DISTRICT
2/12/2015 10:52:18 AM
AUSTIN, TEXAS JEFFREY D. KYLE
Clerk
NOAH S. BUNKER, PAUL CARRELL, EVERETT BREW HOUSTON, JR.,
W. ANDREW BUCHHOLZ, SCOTT J. LEIGHTY, JAD L. DAVIS
AND HOLLY CLAUSE,
Appellants and Cross-Appellees,
v.
TRACY D. STRANDHAGEN,
Appellee and Cross-Appellant.
ON APPEAL FROM THE 353RD JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS
HON. ORLINDA NARANJO, PRESIDING; CAUSE NO. D-1-GN-13-002811
UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLEE’S BRIEF
Daniel H. Byrne
Texas Bar No. 03565600
Dbyrne@fbhh.com
FRITZ, BYRNE, HEAD & HARRISON, PLLC
98 San Jacinto Boulevard, Suite 2000
Austin, Texas 78701
Telephone: (512) 476-2020
Telecopy: (512) 477-5267
TO THE HONORABLE THIRD COURT OF APPEALS:
Appellee Tracy D. Strandhagen (“Appellee”) respectfully requests this Court
for a 10-day extension of time to file Appellee’s Brief and shows the Court the
following:
1. There is no specific deadline to file this motion to extend time. See
TEX. R. APP. P. 38.6(d).
2. Appellants Noah S. Bunker, Paul Carrell, Everett Brew Houston, Jr.,
W. Andrew Buchholz, Scott J. Leighty, Jad L. Davis, and Holly Clause
(“Appellants”) are unopposed to this motion.
3. The Court has the authority under Texas Rule of Appellate Procedure
38.6(d) to extend the time to file a brief.
4. Appellant’s brief was filed on January 14, 2015, after this Court
granted two unopposed extensions of time for Appellant to file such brief.
5. Appellee’s brief is due on February 13, 2015.
6. Appellee requests an additional 10 days to file her brief, extending the
time until February 23, 2015.
7. No extension has been granted to extend the time to file Appellee’s
brief.
8. The requested extension is unfortunately necessitated by several
unavoidable, pre-existing deadlines and professional obligations by Appellee’s
counsel in other matters, all of which have required or will require significant
commitments of time before February 13, 2015.
PRAYER
For these reasons, Appellee Tracy D. Strandhagen asks the Court to grant
her an extension of time to file her brief until February 23, 2015.
CERTIFICATE OF CONFERENCE
Christine E. Burgess, counsel for Appellee conferred with Amanda Taylor,
counsel for Appellant, regarding the Motion to Extend Time to File Appellee’s
Brief, and Ms. Taylor is unopposed to such Motion.
Respectfully submitted,
FRITZ, BYRNE, HEAD & HARRISON, PLLC
98 San Jacinto Boulevard, Suite 2000
Austin, Texas 78701
Telephone: (512) 476-2020
Facsimile: (512) 477-5267
By: /s/ Christine E. Burgess
Daniel H. Byrne
Texas Bar No. 03565600
dbyrne@fbhh.com
Lessie G. Fitzpatrick
Texas Bar No. 24012630
lfitzpatrick@fbhh.com
Christine E. Burgess
Texas Bar No. 00793428
cburgess@fbhh.com
Counsel for Appellee Firstmark Credit Union
CERTIFICATE OF SERVICE
I certify that the foregoing Motion was served on the following counsel of
record on February 12, 2015, by e-service and email.
Amanda G. Taylor
ataylor@textaxlaw.com
MARTENS, TODD, LEONARD & TAYLOR
301 Congress Avenue, Suite 1950
Austin, Texas 78701
Facsimile: (512) 542-9899
Attorney for Appellants/Cross-Appellees
/s/ Christine E. Burgess
Christine E. Burgess