ACCEPTED
06-15-00031-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
10/12/2015 12:00:00 AM
DEBBIE AUTREY
CLERK
No. 06-15-00031-CV
IN THE
FILED IN
COURT OF APPEALS FOR THE 6th COURT OF APPEALS
SIXTH SUPREME JUDICIAL DISTRICT OF TEXASTEXARKANA, TEXAS
AT TEXARKANA, TEXAS 10/12/2015 9:21:00 AM
DEBBIE AUTREY
Clerk
DOUGLAS B. MOSELEY,
Appellant,
vs.
SHERRIE ARNOLD,
Appellee.
Appeal from the 71st District Court
of Harrison County, Texas
Honorable Brad Morin
UNOPPOSED MOTION TO EXTEND
APPELLEE’S BRIEFING DEADLINE
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TO THE HONORABLE COURT OF APPEALS:
COMES NOW, Sherrie Arnold, Appellee in the above-captioned proceeding (the
“Appellee”), and respectfully submits this Unopposed Motion to Extend Appellee’s Briefing
Deadline (the “Motion”).
1. The Appellee respectfully requests an extension of time to file her appellee’s brief
for an additional twenty-one (21) days, through and including November 4, 2015. Appellee’s
brief is currently due October 14, 2015. This is Appellee’s first request for an extension of
briefing deadline in this case.
2. Douglas B. Moseley, the Appellant, consents to the requested extension.
3. Appellee respectfully presents the following facts to the Court as a reasonable
explanation for the additional requested extension of time. In addition to preparing the
appellee’s brief in this case, counsel for Appellee has been required, and will continue to be
required, to devote a substantial amount of time to the following matters:
a. Circle Ridge Production, Inc. v. Great Northern Energy, et al., Cause No. 14-
0460 in the 71st Judicial District Court of Harrison County, Texas: Counsel for
Appellee is counsel for Plaintiff Circle Ridge Production, Inc. and
Counter/Cross-Defendant Bill Briscoe in this Trespass to Try Title, or in the
alternative, Suit to Quiet Title. The case is specially set for jury trial on
October 19, 2015 before the Honorable Brad Morin.
b. Mary Stevens v. AdCorp Outdoor Media, L.L.C., Cause No. 15-0258 in the
71st Judicial District Court of Harrison County, Texas: Counsel for Appellee is
counsel for Plaintiff Mary Stevens in this Declaratory Judgment and Trespass,
or, in the alternative, Partition of Property, and for Injunctive Relief. This
case is set for bench trial before the Honorable Brad Morin on October 27,
2015.
4. The requested enlargement of time, which is unopposed, is not sought for the sake
of delay, but rather is requested for the minimum amount of time necessary for counsel to
properly prepare Appellee’s Brief in this matter.
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Therefore, Appellee prays that this Court grant this Motion for extension of time to
extend the due date for appellee’s brief for twenty-one (21) days until November 4, 2015.
Respectfully submitted,
DEAN A. SEARLE
Texas Bar No. 17956600
RONAN S. SEARLE
Texas Bar No. 24079292
SEARLE & SEARLE, PC
P.O. Box 910
305 West Rusk Street
Marshall, Texas 75671
Phone (903) 935-9772
Fax (903) 935-9790
Dsearle54@gmail.com
Ronan.searle@gmail.com
By: /s/ Ronan S. Searle
Ronan S. Searle
Texas Bar No. 24079292
ATTORNEYS FOR THE APPELLEE
.
CERTIFICATE OF CONFERENCE
I hereby certify that, on September 30, 2015, I conferred with Gerrit M. Pronske, counsel
for Appellant, who indicated that Appellant is unopposed to the extension requested herein.
/s/ Ronan S. Searle
Ronan S. Searle
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CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that, on October 11, 2015, I caused to be served the
foregoing pleading upon the counsel listed below via email and also via the Court’s electronic
transmission facilities.
Gerritt M. Pronske
Melanie P. Goolsby
PRONSKE GOOLSBY & KATHMAN, P.C.
15305 Dallas Parkway, Suite 300
Addison, Texas 75001
Email: gpronske@pgkpc.com
Email: mgoolsby@pgkpc.com
/s/ Ronan S. Searle
Ronan S. Searle
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