ACCEPTED
12-15-00220-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
11/2/2015 4:31:18 PM
Pam Estes
CLERK
No. 12-15-00220-CV
In the FILED IN
12th COURT OF APPEALS
TYLER, TEXAS
Twelfth Court of Appeals 11/2/2015 4:31:18 PM
PAM ESTES
Tyler, Texas Clerk
________________________________
ANNA MARIE INMAN, Appellant
VS.
EQUABLE ASCENT FINANCIAL, LLC, Appellee
________________________________
APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME
TO FILE BRIEF
COMES NOW Anna Marie Inman, Appellant herein, and moves this
Court for an extension of time to file their brief under TRAP 38.6(d), and in
support thereof would show the following:
1. Appellant’s brief is now due on November 2, 2015.
2. Appellant requests a 30-day extension of the deadline for filing her
brief, or until December 2, 2015.
3. Appellant seeks this extension of time for several reasons. First, one
of the attorneys working on the brief, Heather Keegan, has not been able to
work on her assigned issue, because she has been busy dealing with
several hearings and outreach events over the past 3 weeks. Second,
while much of the brief assigned to the undersigned has been completed,
more time is needed to finish some legal research and drafting on the one
issue being handled by the undersigned.
4. No previous extension of time to file a brief has been accorded by this
Court to Appellant. Counsel for Appellee Equable Ascent Financial, LLC
has informed counsel for Appellant that this motion is not opposed.
WHEREFORE, Appellants prays that this Honorable Court grant this
motion and extend the time for filing Appellant’s brief until January 30,
2015, and for such other and further relief to which they may be entitled.
Respectfully submitted,
LONE STAR LEGAL AID
By: /s/ Richard Tomlinson
RICHARD TOMLINSON
1415 Fannin
Houston, Texas 77002
713/652-0077, ext. 1154
Fax: 713/652-3814
State Bar No. 20123500
ATTORNEY FOR APPELLANT
Appellant’s Unopposed Motion for Extension of Time to File Brief
Page 2
CERTIFICATE OF CONFERENCE
On November 2, 2015 pursuant to TRAP 10.1(a)(5), counsel for
Appellant sought to confer with counsel for Appellee, Dan G. Young of
Jenkins, Wagnon & Young, P.C., about the merits of this motion and
whether Appellee would oppose this motion. After leaving a message for
Mr. Young and e-mailing him, he responded by e-mail that he would not
oppose a 30-day extension of time for Appellant to file her brief.
/s/ Richard Tomlinson
Richard Tomlinson
CERTIFICATE OF SERVICE
Pursuant to T.R.A.P. 9.5, I hereby certify that I served a copy of the
foregoing Appellant’s Unopposed Motion for Extension of Time by e-mail,
fax, certified mail, return receipt requested, or by hand delivery, on this the
2nd day of November, 2015, as follows:
Dan G. Young
Jenkins, Wagnon & Young, P.C.
P.O. Box 420
Lubbock, Texas 79408-0420
dgyservice@jwylaw.com
ATTORNEY FOR APPELLEE
/s/ Richard Tomlinson
Richard Tomlinson
Appellant’s Unopposed Motion for Extension of Time to File Brief
Page 3