Billy Fitts and Freida Fitts v. Melissa Richards-Smith, the Law Firm of Gillam & Smith, LLP, E. Todd Tracy, and the Tracy Law Firm

ACCEPTED
06-15-00017-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
8/25/2015 2:49:30 PM
DEBBIE AUTREY
CLERK

No. 06-15-00017-CV

IN THE COURT OF APPEALS FOR THE FILED IN
SIXTH DISTRICT OF TEXAS 6th COURT OF APPEALS
TEXARKANA, TEXAS
AT TEXARKANA
8/25/2015 2:49:30 PM
________________________________________________________________________
DEBBIE AUTREY
Clerk
BILLY FITTS and FREIDA FITTS,
Appellants,
v.
MELISSA RICHARDS-SMITH, THE LAW FIRM OF GILLAM & SMITH, LLP,
E. TODD TRACY, and THE TRACY FIRM, Attorneys at Law,
Appellees.
________________________________________________________________________

On Appeal from the 71st District Court of Harrison County, Texas
Trial Court Cause No. 14-0150
_________________________________________________________________________

UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLY BRIEF OF APPELLANTS

TO THE HONORABLE COURT OF APPEALS:

NOW COMES, Billy Fitts and Freida Fitts, Appellants herein, and pursuant to TEX.

R. APP. P. 10.5(b) and 55.7, files this Unopposed Motion for Extension of Time to File

Reply Brief of Appellants, and as grounds therefor, would respectfully show this Honorable

Court the following:

1. Respondents’ Reply Brief is currently due on Thursday, August 27, 2015.

Appellants request an extension of twelve (12) days from that date to file their Reply Brief,

thereby extending the deadline to Tuesday, September 8, 2015 to file Appellants’ Brief and

would respectfully show that the facts relied upon to reasonably explain the need for an

extension are as follows:

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 (a) Since the appeal was commenced, a significant amount of the undersigned

attorney’s time has been and will be consumed by the following:

• Ms. Rames is appellate counsel for Appellees in Michele Schols v. Michell
Anne Kimball and Kimball-Hicks Partnership currently pending in the Fifth
Court of Appeals, Dallas, Texas, Case No. 05-15-00443-CV. Appellees’ brief
was completed August 19, 2015.

• Ms. Rames is counsel for Plaintiffs in HostingXtreme Ventures v. Bespoke
Group, et al., in the United States District Court for the Northern District of
Texas, Case No. 3:14-cv-01471-M. A considerable amount of time has been
spent on the matter over the past two weeks and a considerable amount of time
will be spent on the matter in the next month to include depositions and
hearings.

2. No prior extensions have been requested or granted to Appellants for their

Reply Brief.

3. This motion is not filed for delay purposes and will not prejudice Appellees.

4. CERTIFICATE OF CONFERENCE: On August 11, 2015, the undersigned

counsel for Appellants conferred with counsel for Appellees, Wade Crosnoe and Lindsay

Nutt, concerning this motion, and the motion is unopposed.

Appellants Billy Fitts and Freida Fitts respectfully pray that this Court grant an

extension of time of twelve (12) days for filing Appellants’ Brief until Tuesday, September

8, 2015.

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 Respectfully submitted,

/s/ Lindsey M. Rames
LINDSEY M. RAMES
State Bar No. 24072295
RAMES LAW FIRM, P.C.
Texas Bar No. 24072295
5661 Mariner Drive
Dallas, TX 75237
Telephone: 214.884.8860
Facsimile: 888.482.8894
Email: lindsey@rameslawfirm.com

CARTER L. HAMPTON
State Bar No. 08872100
HAMPTON & ASSOCIATES, P.C.
1000 Houston Street, Fourth Floor
Fort Worth, TX 76102
Telephone: 817.877.4202
Facsimile: 817.877.4204
Email: clhampton@hamptonlawonline.com

ATTORNEYS FOR APPELLANTS

CERTIFICATE OF SERVICE

I, Lindsey M. Rames, the undersigned attorney, does hereby certify that the foregoing
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF OF
APPELLANTS was served upon counsel for all Appellees via electronic service on August
25, 2015.

/s/ Lindsey M. Rames
LINDSEY M. RAMES

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