ACCEPTED
06-15-00017-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/26/2015 2:59:54 PM
DEBBIE AUTREY
CLERK
No. 06-15-00017-CV
IN THE COURT OF APPEALS FOR THE
FILED IN
SIXTH DISTRICT OF TEXAS 6th COURT OF APPEALS
AT TEXARKANA TEXARKANA, TEXAS
6/26/2015 2:59:54 PM
DEBBIE AUTREY
BILLY FITTS and FREIDA FITTS, Clerk
Appellants,
v.
MELISSA RICHARDS-SMITH, THE LAW FIRM OF GILLAM & SMITH, LLP,
E. TODD TRACY, and THE TRACY LAW FIRM,
Appellees.
On Appeal from the 71st District Court of Harrison County, Texas
Trial Court Cause No. 14-0150
E. TODD TRACY’S AND THE TRACY LAW FIRM’S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE THEIR APPELLEES’ BRIEF
TO THE HONORABLE COURT OF APPEALS:
NOW COMES, E. Todd Tracy and the Tracy Law Firm, Appellees, and pursuant to Rule
10.5(b) and Rule 55.7 of the Texas Rules of Appellate Procedure, file this Unopposed Motion for
an Extension of Time to File their Appellee’s Brief.
1. E. Todd Tracy and the Tracy Law Firm’s brief is currently due on July 8, 2015.
Appellees request a thirty day extension of time, until Friday, August 7, 2015, to file their brief.
2. E. Todd Tracy and the Tracy Law Firm reasonably request this extension of time
because: (i) the Clerk’s Record required numerous supplementations to include the requested
pleadings and exhibits, including a recent filing on June 17, 2015, one week after the Appellants’
E. Todd Tracy’s and The Tracy Law Firm’s Unopposed Motion Page 1
for Extension of Time to File their Appellee’s Brief
Brief was filed, and (ii) Appellees’ counsel will be out of the country and unavailable from June
22-June 26, 2015.
3. Appellees Melissa Richards-Smith and The Law Firm of Gilliam & Smith LLP
are also filing a motion requesting an extension until August 7, 2015 due to their appellate
counsel’s schedule. Granting this extension of time will allow all Appellees to file their
respective briefs at the same time.
4. This request is E. Todd Tracy and the Tracy Law Firm’s first request for an
extension of time. No prior extensions have been requested or granted to Appellees.
5. Appellees request this extension not in order to delay this matter, but due to its’
counsel’s schedule and in the interest of justice. All parties are unopposed to this request for an
extension of time.
For these reasons stated above, E. Todd Tracy and the Tracy Law Firm ask the Court to
grant their unopposed extension of time to file Appellees’ Brief, until August 7, 2015.
Respectfully submitted,
CAMPBELL & CHADWICK, P.C.
_/s/ Lindsay McNutt _________________
BRUCE A. CAMPBELL
STATE BAR NO. 03694500
LINDSAY MCNUTT
STATE BAR NO. 24058823
4201 Spring Valley Rd., Suite 1250
Dallas, TX 75244
Telephone: (972) 277-8585
Facsimile: (972) 277-8586
Email: bcampbell@cllegal.com
Email: lmcnutt@cllegal.com
ATTORNEYS FOR APPELLEES,
E. TODD TRACY AND THE TRACY LAW
FIRM
E. Todd Tracy’s and The Tracy Law Firm’s Unopposed Motion Page 2
for Extension of Time to File their Appellee’s Brief
CERTIFICATE OF CONFERENCE
On June 26, 2015, Lindsay McNutt, counsel for Appellees, conferred with Lindsey Rames,
counsel for Appellants, and Sara Churchin, counsel for the Smith Appellees, regarding this
request for a 30-day extension of time. Both Ms. Rames and Ms. Churchin advised that they are
unopposed to this request for an extension of time.
_/s/ Lindsay McNutt _________________
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of this document was served
pursuant to the Texas Rules of Civil Procedure on the June 26, 2015, as follows:
Lindsey Rames Certified mail, return receipt requested
RAMES LAW FIRM Personal delivery / Hand Delivery
Attorney for Plaintiffs Private delivery / FedEx
5661 Mariner Drive Facsimile transfer
Dallas, Texas 75237 First Class Mail
Attorneys for Appellants E-filing
Carter Hampton Certified mail, return receipt requested
Hampton & Associates Personal delivery / Hand Delivery
Attorney for Plaintiffs Private delivery / FedEx
1000 Houston Street Facsimile transfer
Fort Worth, Texas 76102 First Class Mail
Attorneys for Appellants E-filing
Wade Crosnoe
Shawn Phelan Certified mail, return receipt requested
Tommy Horan Personal delivery / Hand Delivery
THOMPSON COE Private delivery / FedEx
700 North Pearl Street, Suite 2500 Facsimile transfer
Dallas, Texas 75201 First Class Mail
Attorneys for Smith Appellees E-filing
_/s/ Lindsay McNutt _________________
E. Todd Tracy’s and The Tracy Law Firm’s Unopposed Motion Page 3
for Extension of Time to File their Appellee’s Brief