Tami Donald, Jerry Moore, and Summit Spring Water Company, Inc. v. Brian Rhone, BMR Distributing, Inc., Chris Rhone, and Rhone Water Company, Inc. D/B/A Frosty's Water

ACCEPTED
06-15-00052-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
12/10/2015 11:24:12 AM
DEBBIE AUTREY
CLERK

No. 06-15-00052-CV
___________________ FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
IN THE COURT OF APPEALS 12/10/2015 11:24:12 AM
FOR THE SIXTH DISTRICT OF TEXAS DEBBIE AUTREY
AT TEXARKANA Clerk
_____________________________________________________________________________

TAMI DONALD, JERRY MOORE,
and SUMMIT SPRING WATER CO., INC.

Appellants
v.

BRIAN RHONE, CHRIS RHONE,
BMR DISTRIBUTING, INC., and RHONE WATER CO., INC.

Appellees
______________________________________________________________________________

On Appeal from the 336th District Court of Fannin County, Texas
The Honorable Laurine J. Blake, Judge Presiding
______________________________________________________________________________

UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEES’ BRIEF
______________________________________________________________________________

I.

Appellees move for an unopposed extension of time to file their brief and state the following

in support:

UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEES’ BRIEF PAGE -1-
 Appellees’ brief is due to be filed on December 14, 2015. Appellees respectfully request a

thirty-day extension of time, until January 13, 2016, to file their brief. Appellees have not previously

requested an extension of time to file their brief. Appellees are not filing this motion for the purpose

of delay, but in the interest of justice.

II.

Appellees’ counsel is Thomas F. Dunn. Mr. Dunn underwent a double disc spinal fusion

on October 16, 2015. His post operative recovery has limited the amount of time he has been able

to spend in the office to handle client matters. Consequently, Mr. Dunn’s client work load has been

jammed up. Due to the physical limitations on the amount of time he could spend on pending client

matters, Mr. Dunn will be unable to complete Appellees’ brief in this case by the December 14, 2015

deadline.

III.

WHEREFORE, PREMISES CONSIDERED, Appellees pray that this Court enter an order

granting their Unopposed Motion for Extension of Time to File Appellees’ Brief and specifying that

Appellees’ brief be filed on or before January 13, 2016.

Respectfully submitted,

/s/ Thomas F. Dunn
Thomas F. Dunn
State Bar No. 06243300
tomdunn@dunnlawgroup.net
Dunn Law Group, P. C.
3901 W. Pioneer Parkway
Arlington, Texas 76013
(817) 459-0000
(817) 459-0002 facsimile

UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEES’ BRIEF PAGE -2-
 CERTIFICATE OF CONFERENCE

I certify that, on December 9, 2015, I conferred with Appellees’ counsel and he advised that

he is unopposed to the relief sought in this motion.

/s/ Thomas F. Dunn
Thomas F. Dunn

CERTIFICATE OF SERVICE

I certify that, on December 10, 2015, I served a copy of this motion to the following counsel

for Appellants:

Chad M. Ruback
The Ruback Law Firm
8117 Preston Road
Suite 300
Dallas, Texas 75225

served via email to: chad@appeal.pro

/s/ Thomas F. Dunn
Thomas F. Dunn

UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLEES’ BRIEF PAGE -3-