James v. Long v. Southwest Funding, L.P. OneWest Bank, FSB IndyMac Mortgage Services And Deutsche Bank National Trust, Co.

ACCEPTED
03-15-00020-CV
4959347
THIRD COURT OF APPEALS
AUSTIN, TEXAS
4/20/2015 4:28:55 PM
JEFFREY D. KYLE
CLERK
CAUSE NO. 03-15-00020-CV

IN THE COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
FOR THE 3rd JUDICIAL DISTRICT OF TEXAS AUSTIN, TEXAS
HOUSTON, TEXAS 4/20/2015 4:28:55 PM
___________________________ JEFFREY D. KYLE
Clerk
JAMES V. LONG,
ONEWEST BANK, FSB. et al
Appellee
___________________________

On Appeal from the 126th Judicial District Court
Travis County, Texas
Trial Court Cause No. D-1-GN-1 0-003483
___________________________

UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF

1. This case is on appeal from the 126th Judicial District Court of Travis

County, Texas in trial court cause number Trial Court Cause No. 2013-00767

2. The transcript was filed on February 18, 2015. Appellants brief was due

March 20, 2015.

3. Appellant requests an extension of time of on month from the due date,

i.e. until Monday, April 20, 2015.

4. No prior extension to file the brief has been received in this cause.

5. The need for the extension is as follows. Appellant’s counsel is a solo

practitioner. He had already prepared a draft response to the issues on appeal, but

needed to incorporate the record and additional case sites, and to put it in the form

required by the court. Counsel had regular clients experience unexpected complex
criminal matters which required Counsel to act immediately to protect their

interests. Counsel also had to prepare three complex motions and responses to

summary judgment. This in addition to counsel’s normal case load prevented him

from completing a full brief. Appellant moves for an extension to April 20, 2015.

WHEREFORE, Appellant prays that the court grant it an extension of time

to file its brief and for such other and further relief as is just.

Respectfully submitted,

____/S/James D. Pierce_______________
JAMES D. PIERCE
State Bar No. 15994500
Comerica Bank Building
One Sugar Creek Center Blvd., Suite 1080
Sugar Land, Texas 77478-3560
(713) 650-0150 office
(713) 650-0146 facsimile
jim@jamespierce.com email
ATTORNEY FOR APPELLANT

CERTIFICATE OF CONFERENCE

The motion is unopposed.
 CERTIFICATE OF SERVICE

In compliance with Texas Rules of Appellant Civil Procedure, on April 1,
2015, this pleading was served upon all parties and counsel of record
electronically.

_____/S/James D. Pierce_________________
JAMES D. PIERCE