ACCEPTED
12-14-00156-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
7/6/2015 1:48:06 PM
CATHY LUSK
CLERK
UNITED STATES TWELFTH COURT OF APPEALS FILED IN
12th COURT OF APPEALS
TYLER, TEXAS
INEZ MANIGAULT, §
7/6/2015 1:48:06 PM
Plaintiff, §
§ CATHY S. LUSK
Clerk
Vs. § Case No. 12-14-00156-CV
§
JANE THORN-HENDERSON §
APPELLEE’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THIS COURT:
Jane Thorne-Henderson requests an order extending time to file her brief as follows:
Appellee requests a one week extension of time to file her brief because counsel for
appellee was originally scheduled to attend trial of Cause No: DC-13-07008, styled Maria
Alonzo v. Linda Meredith, in the 191st District Court of Dallas County, Texas; and then the day
after, on Tuesday, June 7, 2015, was scheduled to begin an arbitration proceeding with the
American Arbitration Association styled Mike Pile BMW v. Lay Construction, LLC, Cause No.
01-14-0001-7427. Both those matters resolved during the afternoon of Thursday July 3, 2015.
Because of these other matters, counsel was unable to complete his client’s response by the
deadline, today.
Appellee’s brief in the in this matter is due today, July 6, 2015. By this motion, appellee
requests an order extending the time to file appellee’s brief to Monday, July 13, 2015.
Appellee has requested no previous extension of time in this appellate cause. Counsel for
appellee requires additional time in which to file this brief because of the following
circumstances described supra.
No party will be prejudiced by the extension requested herein.
1
Conference
Counsel attempted to confer with pro se Appellant on July 6, 2015, and Appellant
counsel did not respond at all. Counsel has therefore received no agreement or opposition to
this motion.
Prayer for Relief
Therefore, appellee respectfully requests that this Court issue an order granting the
extension the time for the filing of the appellant’s brief in the above case to Monday July 13,
2015.
Respectfully submitted,
WHITE SHAVER, P.C.
205 W. Locust Ave.
Tyler, Texas 75702
Telephone: 903/533-9447
Telefax: 903/595-3766
By:
Adam B. Allen
State Bar No. 24038738
AAllen@whiteshaverlaw.com
ATTORNEY FOR APPELLEE
CERTIFICATE OF SERVICE
I do certify that a true and correct copy of the foregoing Response was delivered to all
counsel and parties of record, via mail in accordance with the Texas Rules of Civil Procedure on
this 6TH day of July, 2015.
_________________________________
Adam B. Allen
2
CERTIFICATE OF CONFERENCE
I hereby certify that on July 6, 2015, I attempted to confer with pro-se appellant regarding
the motion for extension of time, and appellant did not respond.
________________________________
Adam Allen
3