ACCEPTED
06-15-00031-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
8/20/2015 9:09:51 PM
DEBBIE AUTREY
CLERK
No. 06-15-00031-CV
IN THE
FILED IN
COURT OF APPEALS FOR THE 6th COURT OF APPEALS
SIXTH SUPREME JUDICIAL DISTRICT OF TEXASTEXARKANA, TEXAS
AT TEXARKANA, TEXAS 8/21/2015 7:50:00 AM
DEBBIE AUTREY
Clerk
DOUGLAS B. MOSELEY,
Appellant,
vs.
SHERRIE ARNOLD,
Appellee.
Appeal from the 71st District Court
of Harrison County, Texas
Honorable Brad Morin
UNOPPOSED MOTION TO EXTEND
APPELLANT’S BRIEFING DEADLINE
COMES NOW Douglas B. Moseley, Appellant in the above-captioned proceeding (the
“Appellant”), and respectfully submits this Unopposed Motion to Extend Appellant’s Briefing
Deadline (the “Motion”).
1. The Appellant respectfully requests an extension of time to file its appellant’s
brief for an additional 21 days, through and including September 11, 2015. Appellant’s brief is
currently due August 21, 2015. This is Appellant’s first request for an extension of briefing
deadline in this case.
2. Sherrie Arnold, the Appellee, consents to the requested extension.
3. Appellant respectfully represents the following facts to the Court as a reasonable
explanation for the additional requested extension of time. In addition to preparing the
appellant’s brief in this case, counsel for Appellant has been required, and will continue to be
required, to devote a substantial amount of time to the following matters:
a. Kim v. Dome Entertainment Center, Inc., Case No. 3:15-cv-00452-D in the
United States District Court for the Northern District of Texas, Dallas Division:
Counsel for the Appellant is counsel for the debtor/appellant in this appeal from
a bankruptcy case; oral argument is set for September 4, 2015.
b. In re Couture Hotel Corporation, Case No. 14-34874-bjh-11 in the United States
Bankruptcy Court for the Northern District of Texas, Dallas Division: Counsel
for the Appellant is counsel for this Chapter 11 debtor-in-possession and
concluded a week-long, heavily contested confirmation trial in this Chapter 11
case on July 31, 2015 and has submitted a number of post-confirmation briefs in
the weeks following the conclusion of the confirmation trial.
c. Kirtland Realty Group, LP v. Gaubert, Cause No. DC-14-12750 in the 193rd
Judicial District Court, Dallas County, Texas: Non-jury trial set for September
27, 2015; counsel for Appellant represents the plaintiff and related counter- and
cross-defendants and must attend to trial preparation as well as the drafting and
oral argument of a motion to reconsider summary judgment order.
4. The requested enlargement of time, which is unopposed, is not sought for the sake
of delay, but rather is requested for the minimum amount of time necessary for counsel to
properly prepare Appellant’s principal brief in this matter.
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Therefore, Appellant prays that this Court grant this motion for extension of time to
extend the due date for Appellant’s brief for 21 days.
Respectfully submitted,
/s/ Gerrit M. Pronske
Gerrit M. Pronske
State Bar No. 16351640
Melanie P. Goolsby
State Bar No. 24059841
PRONSKE GOOLSBY & KATHMAN, P.C.
15305 Dallas Parkway, Suite 300
Addison, Texas 75001
(214) 658-6500 – Telephone
(214) 658-6509 – Telecopier
Email: gpronske@pgkpc.com
Email: mgoolsby@pgkpc.com
ATTORNEYS FOR THE APPELLANT
CERTIFICATE OF CONFERENCE
I hereby certify that, on August 17, 2015, I conferred via email with Dean A. Searle,
counsel for the appellee, who indicated that appellee is unopposed to the extension requested
herein.
/s/ Gerrit M. Pronske
Gerrit M. Pronske
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CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that, on August 20, 2015, I caused to be served the
foregoing pleading upon the counsel listed below via email and also via the Court’s electronic
transmission facilities.
Deane A. Searle
Searle & Searle, PC
P.O. Box 910
305 West Rusk Street
Marshall, Texas 75671
Email: dsearle54@gmail.com
/s/ Gerrit M. Pronske
Gerrit M. Pronske
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