ACCEPTED
12-15-00119-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
12/21/2015 3:10:09 PM
Pam Estes
CLERK
NO. 12-15-00119-CV FILED IN
12th COURT OF APPEALS
IN THE TYLER, TEXAS
TWELFTH COURT OF APPEAIS 12/21/2015 3:10:09 PM
TYLERTEXAS PAM ESTES
Clerk
DEBR¿.DENTLE.AI AIK/A
DEBBIE D. LEAI, AND TANGO
TRÂNSPORT, INC., AND TANGO
TRANSPORT, TT,C.
vs
JAMES JORDAN
Appealed ftom the 115ù District Court
Upshut County, Texas
Cause No. 588-12
Honotable Lauten Parish, Ptesiding Judge
MOTION TO EXTEND TIME, FOR FILING OF
APPELLEE'S BRIEF
"Rust''Phenix
J. R.
No. 15908300
State Bar
PHENIX & CRUMP
P. O. Box 1005
Ilenderson, Texas 7 5653
903.657.3595
903.657 .3598 - Facsimile
ATTORNEY FOR APPF'J J EE
MOTION TO EXTEND TIME FOR FILING OF
APPELLEE'S BRIEF
TO THE HONORABLE COURT:
Now comes Appellee,JAMESJORDAN, who makes and files this Motion to Extend Time for
Filiog of Âppellee's Brief and for such would show the Court the following:
7.
The cunent deadline for fi.ling Appellee's Bdef is January 4,2076. Appellant's Brief was filed
on Decemb er 2,2075 and this date is calculated allowing fot additional days as the thirty day deadline
ftom the fiting of Brief expires on Saturday,January 2,2016.
'\ppellant's
2.
Appellee requests the Court to graît a thirty (30) day extension.
3.
Appellee requests this extension of time fot the following reasons:
a.. Appellee's counsel has been unusually busy during the first part of Decembet
with hearings and yeat end business;
b. Appellee's counsel has a planned vacation ftom Decernber 24,2015 through
January 4,2076;and.
c. The staff of Appellee's counsel will also be vacationing during that time fot the
holidays.
Thetefote, Appellee's counsel will not have his normal staff avatlable to ptepare, complete, and
file Appellee's Brief dudng the time from December24,2075 toJanuzry 4,201,6.
4.
This is the first extension tequested by,\ppellee's counsel. This request for the extension is not
sought fot delay only, but that justice may be done.
CERTIFICATE OF CONFERENCE
Appellee's counselhas conferedwithAppellant's counselbyphone on December27,2075,and
was informed that Appellant's counsel does not oppose the requested extension.
WHEREFORE,PREMISES CONSIDERED,JAMESJORDAN,,{.ppellee,requests theCourt
to extend the time fot filing his bdef in this mattet by thitty (30) days to February 4,2076. Appellee
requests such othet and further telief to which Appellee may be jusdy entitled and for which Appellee
will evet ptay.
Resp ectfu lly submitted,
PHE,NIX & CRUMP
118 S. MAIN
POST OF'F'ICE, BOX 1OO5
HE,NDE,RSON, TEXAS 7 5654
903/6s7-3s9s
903 / 6s7 -3598 - FACSTMTLE
BY: /s/ T. R. "Rustv" Phenix
J. R. "RUSTY" PHENIX
State Bat No. 15908300
Attomey fot Appellee, tames lotdan
CERTIFICATE OF SERVICE
I hereby certifir thatz true and coffect copy of the above and fotegoinghas been forwatded on
this the 21"' day of Decemb.g 2075 zddressed/ditected as follows:
Matthew Thigpen
I-ADD & THIGPE,N, P.C.
235 S. Btoadwty, Suite 200
Tylet, Texas 75702
Facsimile: 903 / 7 05-7 221
R.'
J. R. "RUSTY" PHENIX