ACCEPTED
06-15-00017-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/26/2015 3:08:41 PM
DEBBIE AUTREY
CLERK
No. 06-15-00017-CV
IN THE COURT OF APPEALS FOR THE FILED IN
6th COURT OF APPEALS
SIXTH DISTRICT OF TEXAS TEXARKANA, TEXAS
AT TEXARKANA 6/26/2015 3:08:41 PM
DEBBIE AUTREY
Clerk
BILLY FITTS and FREIDA FITTS,
Appellants,
v.
MELISSA RICHARDS-SMITH, THE LAW FIRM OF GILLAM & SMITH,
LLP, E. TODD TRACY, and THE TRACY FIRM, Attorneys at Law,
Appellees.
On Appeal from the 71st District Court of Harrison County, Texas
Trial Court Cause No. 14-0150
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLEES
TO THE HONORABLE COURT OF APPEALS:
Melissa Richards-Smith and the Law Firm of Gillam & Smith, LLP
(Appellees) file this Unopposed Motion for Extension of Time to File Appellees’
Brief and would respectfully show:
Appellants filed their brief on June 8, 2015, making Appellees’ brief due on
July 8, 2015. See Tex. R. App. P. 38.6(b). Appellees wish to extend that deadline
by thirty days, or until August 7, 2015. See Tex. R. App. P. 38.6(b). This is
Appellees’ first request for an extension of time to file its Appellees’ Brief.
This extension of time is necessary because the attorney primarily
responsible for drafting the brief, Wade Crosnoe, will be on a previously scheduled
vacation on the current filing deadline and the preceding holiday weekend.
Additionally, Mr. Crosnoe’s work on other cases will prevent him from preparing
the brief by the current deadline, including (1) drafting of post-submission briefing
invited by the Court in an appeal styled Allstate Insurance Co., et al. v. Michael
Kent Plambeck, D.C., et al., No. 14-10574, in the United States Court of Appeals
for the Fifth Circuit; and (2) work on various responses and replies in connection
with a motion to compel discovery and a motion to strike objections, and
attendance at the June 16, 2015 hearing on those motions, in a case styled Munif
Ali Gattas Bultaif, et al. v. Bridgestone/Firestone, Inc., et al., Cause No. 04-6262-
J, in the 191st District Court of Dallas County, Texas.
Appellants Billy Fitts and Freida Fitts are not opposed to this motion.
Appellees E. Todd Tracy and the Tracy Firm are also unopposed.
For these reasons, Appellees respectfully request that the Court grant this
motion and extend the deadline to file its Brief until August 7, 2015. Appellees
also request all other relief to which it is justly entitled.
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Respectfully submitted,
THOMPSON, COE, COUSINS & IRONS L.L.P.
By: /s/ Wade Crosnoe
Wade C. Crosnoe
State Bar No. 00783903
701 Brazos, Suite 1500
Austin, TX 78701
Telephone: (512) 703-5078
Fax: (512) 708-8777
E-mail: wcrosnoe@thompsoncoe.com
Shawn W. Phelan
State Bar No. 00784758
Plaza of the Americas
700 N. Pearl Street, Twenty-Fifth Floor
Dallas, TX 75201-2832
Telephone: (214) 871-8245
Telecopy: (214) 871-8209
E-Mail: sphelan@thompsoncoe.com
Attorneys for Appellees Melissa Richards-
Smith and Law Firm of Gillam & Smith,
LLP
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CERTIFICATE OF SERVICE
I certify that a true and correct copy of this Unopposed Motion for Extension
of Time to File Brief of Appellees was served on June 26, 2015, via electronic
service or email, to the following counsel:
Lindsey M. Rames
Rames Law Firm, P.C.
5661 Mariner Drive
Dallas, TX 75237
Telephone: 214.884.8860
Facsimile: 888.482.8894
Email: lindsey@rameslawfirm.com
Carter L. Hampton
Hampton & Associates, P.C.
1000 Houston Street, Fourth Floor
Fort Worth, TX 76102
Telephone: 817.877.4202
Facsimile: 817.877.4204
Email: clhampton@hamptonlawonline.com
Attorneys for Appellants,
Billy Fitts and Freida Fitts
Bruce A. Campbell
Campbell & Chadwick
4201 Spring Valley Road, Suite 1250
Dallas, TX 75244
Attorney for Appellees E. Todd Tracy
and The Tracy Firm, Attorneys at Law
/s/ Wade C. Crosnoe
Wade C. Crosnoe
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