CorpSol, Inc. Corporate Solutions, Inc. Corporate Solutions Services Inc. And 4XE, Inc. v. Texas Property and Casualty Insurance Guaranty Association

ACCEPTED
03-15-00074-CV
5987478
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/8/2015 4:37:41 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00074-CV
FILED IN
In the Third Court of Appeals 3rd AUSTIN,
COURT OF APPEALS
TEXAS
Austin, Texas 7/8/2015 4:37:41 PM
JEFFREY D. KYLE
Clerk

CORPSOL, INC., CORPORATE SOLUTIONS, INC.,
CORPORATE SOLUTIONS SERVICES, INC., AND 4XE, INC.

Appellants

V.

TEXAS PROPERTY AND CASUALTY INSURANCE GUARANTY ASSOCIATION,

Appellee

APPEAL FROM CAUSE NO. D-1-GN-09-001428
250TH JUDICIAL DISTRICT COURT OF TRAVIS COUNTY, TEXAS
HON. JOHN DIETZ PRESIDING

UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

Appellants CorpSol, Inc., Corporate Solutions, Inc., Corporate Solutions

Services, Inc., and 4XE, Inc., file this motion requesting a thirty-day extension of

time for filing their opening brief in the above-referenced appeal. Appellants

respectfully show:

1. Appellants’ brief is currently due on July 13, 2015.
 2. Appellants request a 30-day extension of time, or until August 12,

2015, for filing their brief. Appellants have requested no previous extensions.

3. Out of town travel and the demands of other cases have made this

motion necessary. From June 21 through June 26, 2015, the undersigned counsel

chaperoned a youth mission trip that precluded him from performing any

substantive work over that period. Since then, counsel has been occupied with the

following matters:

• a petition for writ of mandamus and emergency motion for temporary
relief filed on July 1, 2015 in No. 03-15-00406-CV, In re Brad
Haskins and Sue Miller;

• a petition for writ of mandamus and emergency motion for temporary
relief filed on July 1, 2015 with the Eighth Court of Appeals in No.
08-15-00406-CV, In re Mario Alonzo Cisneros;

• a petition for review filed on July 6, 2015 with the Texas Supreme in
No. 15-0338, Tom Bennett and James B. Bonham Corp. v. Larry
Wayne Grant; and

• a reply brief to be filed by July 10, 2015 with the Fourteenth Court of
Appeals in No. 14-15-00024-CV, Microsoft Corporation v. Michael
Mercieca.

4. This case has not been set for submission. Therefore, no unnecessary

delay will result from the granting of this extension.

5. Appellee does not oppose the relief sought in this motion.

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 CONCLUSION AND PRAYER

For these reasons, appellants respectfully request that the Court grant this

motion for extension of time, thus making their opening brief due on August 12,

2015. Appellants request all other appropriate relief to which they are entitled.

Respectfully submitted,

SMITH LAW GROUP LLLP

/s/D. Todd Smith
D. Todd Smith
State Bar No. 00797451
todd@appealsplus.com
Brandy Wingate Voss
State Bar No. 24037046
brandy@appealsplus.com
1250 Capital of Texas Highway South
Three Cielo Center, Suite 601
Austin, Texas 78746
(512) 439-3230
(512) 439-3232 (fax)

Counsel for Appellants CorpSol, Inc.,
Corporate Solutions, Inc., Corporate
Solutions Services, Inc., and 4XE, Inc.

CERTIFICATE OF CONFERENCE

In compliance with Texas Rule of Appellate Procedure 10.1(a)(5), I certify

that I conferred with appellee’s lead counsel, Dan Price, about this motion. Mr.

Price informed me that appellee does not oppose the relief requested in this

motion.

/s/ D. Todd Smith
D. Todd Smith

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 CERTIFICATE OF SERVICE

On July 8, 2015, in compliance with Texas Rule of Appellate Procedure 9.5,

I served this document by e-service and e-mail to:

Dan J. Price
STONE LOUGHLIN & SWANSON LLP
P.O. Box 30111
Austin, Texas 78755
dprice@slsaustin.com
Counsel for Appellee

/s/D. Todd Smith
D. Todd Smith

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