Stacey Scott v. Larry Furrow and Keller Williams Legacy Group

ACCEPTED
04-15-00074-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
11/2/2015 9:03:24 AM
KEITH HOTTLE
CLERK

CAUSE NO. 04-15-00074-CV

FILED IN
4th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE FOURTHSANCOURT
ANTONIO, TEXAS
OF APPEALS DISTRICT OF TEXAS, SAN ANTONIO, TEXAS
11/2/2015 9:03:24 AM
KEITH E. HOTTLE
Clerk

STACEY SCOTT,
Appellant

vs.

LARRY FURROW AND KELLER WILLIAMS LEGACY GROUP,
Appellees

ON APPEAL FROM THE 25™ JUDICIAL
DISTRICT COURT OF GUADALUPE COUNTY, TEXAS
CAUSE NO. 13-1125-CV-A

UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE BRIEF OF APPELLEES

TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS OF
THE STATE OF TEXAS, SAN ANTONIO, TEXAS:

NOW COME LARRY FURROW and KELLER WILLIAMS LEGACY

GROUP, Appellees in this cause, and file this their Unopposed Motion for Extension

of Time to File Brief; and in support thereof would respectfully show this Honorable

Court as follows: .
 I.

Appellee's Brief is currently due on November 2, 2015. Appellant was

previously granted several unopposed extensions in which to file her brief. This is the

first request for an extension of the deadline for filing Appellees' Brief herein.

II.

In addition to the undersigned counsel's normally heavy trial and appellate

workload, counsel is involved in complex litigation pending in Cause No. 5-15-CV-

0284-RP in the Western District of Texas styled Nvision Biomedical Technologies,

LLC vs. JALEX Medical, LLC

III.

By reason of the foregoing, Appellees respectfully request of this Honorable

Court a 21-day extension until Monday, November 23, 2015 in which to file the Brief

ofAppellees in this matter. This extension of time will not work a hardship upon any

party, and will facilitate the presentation of briefs sufficient to apprise the Court of the

pertinent facts and law governing the issues at bar and to assist this Honorable Court

in a correct and complete resolution thereof.

IV.

Pursuant to Rule 10.1(a)(5), Tex. R. App. P., the undersigned counsel for

Appellees has conferred with Mr. Frederick Junldn, counsel for Appellant, who stated
that he is not opposed to this motion.

This extension is not sought for delay only, but so that justice may be done.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray that

this Unopposed Motion for Extension to Time to File Brief be granted; and for such

other and further relief, at law or in equity, to which Appellees might show themselves

justly entitled.

Respectfully submitted,

THORNTON, BIECHLIN, SEGRATO,
REYNOLDS & GUERRA, L.C.
100 N.E. Loop 410, Suite 500
San Antonio, TX 78216
Telephone: 210/342-5555; 210/525-0666 fax

By: sA^auehan E. Waters
Vaughan E. Waters
State Bar No. 20916700
ATTORNEYS FOR APPELLEES
 CERTIFICATE OF SERVICE

A true and correct copy of the above and foregoing instrument has been
forwarded to the undersigned party on the 2nd day of November, 2015.

Via e-service

Mr. Frederick Junldn
Andrews Kurth LLP
600 Travis St, Suite 4200
Houston'/TX 77002

Attorneys for Appellant.

sA^aughan E. Waters
Vaughan E. Waters