Jerry Scarbrough, Denise Steele, and Melissa Victoria Deaton v. Helen Purser, Sue E. Purser A/K/A Sue E. Van Zanten, Gary W. Purser, Jr., Joann M. Purser, and Elizabeth H. Tipton

ACCEPTED
03-13-00025-CV
6655462
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/26/2015 10:19:57 AM
JEFFREY D. KYLE
CLERK
No. 03-13-00025-CV
In the Third Court of Appeals FILED IN
3rd COURT OF APPEALS
Austin, Texas AUSTIN, TEXAS
8/26/2015 10:19:57 AM
Jerry Scarbrough, et al JEFFREY D. KYLE
Clerk
Appellant

v.

Helen Purser, et al.
Appellee

On Appeal from the 146th Judicial District Court of
Bell County, Cause No. 236,117-B

APPELLANTS’ UNOPPOSED MOTION FOR
TIME TO BE ADDED TO ORAL ARGUMENT

TO THE HONORABLE COURT OF APPEALS:

COME NOW, Jerry Scarbrough, Melissa Deaton, and Denise Steele

and file this brief requesting that the Court add ten minutes per side to the

oral argument of this Case. Appellants would show:

1. This Motion is unopposed.

2. Appellants are Jerry Scarbrough, Melissa Deaton and Denise Steele.
 3. Appellees are the Purser Family: Helen Purser, Bubba Purser, JoAnn

Purser, Elizabeth Tipton, and Sue Purser Van Zanten.

4. Oral Argument is currently set in Belton, Texas for October 22, 2015. The

amount of time allotted is twenty minutes per side.

5. Appellants seek to have the Court increase their argument time, and that of

the Purser Family, to thirty minutes. The reason for this is the number of

causes of action involved and the number of points of error briefed. The Court

is asked to take notice that almost thirty points of error were briefed and not

all points of error are identical for the three appellants or three appellees. If

the Court increases time to thirty minutes a side, this will only provide a little

over two minutes of discussion per point if the Court seeks discussion or has

questions on only half the points.

CONCLUSION AND PRAYER

This is an involved case with a 34 volume record, many causes of action, and

almost thirty points of error. Only twenty minutes of argument per side has been

allotted. Appellants seek more time.

WHEREFORE, PREMISES CONSIDERED, Appellants ask this Court to

allow for thirty minutes argument per side and for such other relief as may be just.

Respectfully submitted,

____/s/ MB CHIMENE__________
 THE CHIMENE LAW FIRM
Michele Barber Chimene
TBN 04207500
2827 Linkwood Dr.
Houston, TX. 77025
PH 832 940-1471
No fax available
michelec@airmail.net

CERTIFICATE OF CONFERENCE

On August 24, 2015, the undersigned contacted the law office of Daryl Moore,
counsel for Appellees to determine whether he was in opposition to this Motion. He
is not opposed as long as both sides get increased time.

______/s/ MB CHIMENE

CERTIFICATE OF SERVICE

By my electronic signature, the undersigned certifies that she has served a
copy of this Motion on Daryl L. Moore, daryl@heightslaw.com, JoAnn
Storey, storeyj@heightslaw.com, and Jack R. Crews,
jackcrews@bcswlaw.com via ECF and/or email on this the 25th of August
2015.
_______/s/ MB CHIMENE________