ACCEPTED
03-15-00083-CV
5595846
THIRD COURT OF APPEALS
AUSTIN, TEXAS
6/9/2015 10:06:51 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00083-CV FILED IN
3rd COURT OF APPEALS
___________________________________________________________
AUSTIN, TEXAS
6/9/2015 10:06:51 AM
In the Third District Court of Appeals JEFFREY D. KYLE
Houston, Texas Clerk
___________________________________________________________
CRAIG A. WASHINGTON,
Appellant,
vs.
COMMISSION FOR LAWYER DISCIPLINE,
Appellee.
___________________________________________________________
UNOPPOSED MOTION OF CRAIG A. WASHINGTON TO
EXTEND DEADLINE FOR PRINCIPAL BRIEF
___________________________________________________________
Appellant Craig A. Washington asks that this Court extend for thirty (30)
days the deadline for the filing of his principal brief as the appellant in the
above-captioned case, making the new briefing deadline August 3, 2015. In
support Mr. Washington states:
1. This is an appeal from a final judgment signed January 8, 2015. The
completed clerk’s record was filed June 2, 2015, and the reporter’s record was
filed May 15, 2015. Therefore, the principal brief of the appellant is due July 2,
2015. TEX. R. APP. P. 38.6(a). This court can extend that deadline. Id. 38.6(d). This
is the appellants’ first request to extend the deadline, and it is unopposed.
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2. Counsel for Mr. Washington, John MacVane, will be responsible for
the initial drafting of the brief and has a long-scheduled vacation the week of
July 2. In addition, Mr. MacVane has significant responsibility for the drafting of
a brief due June 23, 2015, a week before Mr. Washington’s deadline in this case.
That brief, due in Crimson Exploration, Inc., et al. v. Magnum Producing, LP, No.
12-15-13, in the Thirteenth Court of Appeals, involves a complex appeal of an oil-
and-gas title dispute with a 4,265 page clerk’s record.
3. In order to adequately focus on the briefing in this case and to
accommodate Mr. MacVane’s other briefing obligations and long-standing
vacation plans, Mr. Washington requests a 30-day extension of the deadline for
his appellant’s brief. A 30-day extension of the briefing deadline would make
appellants’ brief due on Monday, August 2, 2015.
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Request for Relief
For the above reasons, Craig A. Washington asks this Court to extend for
30 days the deadline for the filing of his principal brief in this appeal, making the
new deadline August 3, 2015.
Respectfully submitted,
/s/ John MacVane Gardere Wynne Sewell LLP
Michael A. Stafford 1000 Louisiana, Suite 3400
Texas Bar No. 18996970 Houston, Texas 77002-5007
Katharine David Tel: 713.276.5500
Texas Bar No. 24045749 Fax: 713.276.5555
John MacVane mstafford@gardere.com
Texas Bar No. 24085444 kdavid@gardere.com
jmacvane@gardere.com
ATTORNEYS FOR
CRAIG A. WASHINGTON, APPELLANT
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CERTIFICATE OF SERVICE
I certify that a copy of this document was served on June 9, 2015, by
delivery to the following counsel via the Electronic Filing Manager:
Cynthia Canfield Hamilton
Office of the Chief Disciplinary
Counsel
State Bar of Texas
Post Office Box 12487
Austin, Texas 78711
chamilton@texasbar.com
/s/ John MacVane
John MacVane
Certificate of Conference
The parties’ counsel have conferred regarding the relief requested in this
motion. Counsel for the appellee—Commission for Lawyer Discipline—
indicated that it will not oppose this request for relief.
/s/ John MacVane
John MacVane
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