ACCEPTED
03-14-00515-CV
4682491
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/27/2015 7:21:42 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00515-CV
Tr Ct No. D-1-GN-14-001581
FILED IN
3rd COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
FOR THE THIRD DISTRICT OF TEXAS 3/27/2015 7:21:42 PM
JEFFREY D. KYLE
Clerk
Salvatore Magaraci and Estate Protection Planning
Corporation, appellants
v.
Eduardo S. Espinosa in his Capacity as Receiver of
Retirement Value, LLC, appellee
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ BRIEF
TO THE THIRD COURT OF APPEALS:
Appellants, Salvatore Magaraci and Estate Protection Planning
Corporation, file this motion for extension of time to file Appellants’ Brief
under Rules 10.1, 10.5(b), and 38.6(d) of the Texas Rule of Appellate
Procedure, and requests the Court to extend the deadline for filing the
appellants’ brief from March 11, 2015 until March 27, 2015. In support of
this motion appellants show:
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I.
This is an appeal from the final judgment after a partial summary
judgment and bench trial in a receivership proceeding. Appellants’ Brief
was filed today.
II.
This is appellants’ first request for an extension of time to file
Appellants’ Brief.
III.
The undersigned Timothy Hootman, underestimated the complexity
of the record and the time necessary to complete the brief, and therefore
requests the additional 16 days. The Appellants’ Brief has been filed
contemporaneously with this motion.
WHEREFORE, appellants, Salvatore Magaraci and Estate Protection
Planning Corporation, pray that this motion be granted and that the Court
extend the time to file Appellants’ Brief from to March 11, 2015, until March
27, 2015.
Respectfully submitted,
/s/Timothy A. Hootman
Timothy A. Hootman, SBN 09965450
2402 Pease St
Houston, TX 77003
713.247.9548; 713.583.9523 (f)
E-mail: thootman2000@yahoo.com
ATTORNEYS FOR APPELLANTS
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CERTIFICATE OF SERVICE
I hereby certify that, in accordance with Rule 9.5 of the Texas Rules of
Appellate Procedure, I have served the forgoing document upon the following
attorneys by personal mail, commercial delivery service, fax, or electronic service:
John W. Thomas
GEORGE, BROTHERS, KINCAID & HORTON, LLP
114 West 7th St, Ste 1100
Austin, TX 78701
Dated: March 27, 2015.
/s/Timothy A. Hootman
Timothy A. Hootman
CERTIFICATE OF CONFERENCE
The undersigned has attempted to communicate with appellees
lawyers by email and has not yet received confirmation as to whether they
are opposed. A supplemental certificate will be filed upon confirmation.
/s/ Timothy A. Hootman
TIMOTHY A. HOOTMAN
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