Thomas D. Young A/K/A T. David Young v. JP Morgan Chase Bank, N.A.

ACCEPTED
03-15-00261-CV
6631069
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/24/2015 6:06:02 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00261-CV

FILED IN
In the Third Court of Appeals 3rd COURT OF APPEALS
AUSTIN, TEXAS
8/24/2015 6:06:02 PM
Austin, Texas
JEFFREY D. KYLE
Clerk

THOMAS D. YOUNG A/K/A T. DAVID YOUNG, APPELLANT

v.

JP MORGAN CHASE BANK, N.A., APPELLEE

APPEAL FROM CAUSE NO. D-1-GN-12-000590
126TH DISTRICT COURT OF TRAVIS COUNTY, TEXAS
HON. DARLENE BYRNE PRESIDING

APPELLANT’S THIRD MOTION FOR EXTENSION OF TIME TO FILE
BRIEF

Stephen Casey
Texas Bar No. 24065015
ORAL
CASEY LAW OFFICE, P.C. ARGUMENT
595 Round Rock West Drive REQUESTED
Suite 102
Round Rock, Texas 78681
Telephone: 512-257-1324
Fax: 512-853-4098
stephen@caseylawoffice.us

Counsel for Appellant
Thomas D. Young a/k/a T. David Young

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 GROUNDS FOR MOTION

1. Appellant’s Brief is due to be filed in Court on August 24, 2015.

2. Appellant’s counsel lacks the clerk’s record.

3. Appellant’s counsel, upon discovery of the missing record, immediately
requested the record via phone call to the court. Appellant’s office left a message
with the court.

4. Appellant is asking for an extension until August 27, 2015, to permit receipt of
the clerk’s record and appropriate citation to the record in the brief.

5. This is Appellant’s third request for an extension. The previous two requests
(the first due to several concurrent brief deadlines, and the second due to a
family crisis) were graciously unopposed. This brief request is not for the
purposes of delay, is for three (3) days, and serves the interest of justice in having
the case considered on the merits of the appeal with appropriate citations to the
record.

PRAYER

For the foregoing reasons, Appellant prays the Court will grant the motion.

Respectfully submitted,

/s/ Stephen Casey

Stephen Casey
Texas Bar No. 24065015

595 Round Rock West Drive, Suite 102
Round Rock, Texas 78681
Telephone: 512-257-1324
Fax: 512-853-4098
info@caseylawoffice.us

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 CERTIFICATE OF CONFERENCE

I hereby certify that I noticed opposing counsel, Marcie L. Schout, via e-mail
on August 24, 2015. It was past 5:00 pm when the message was sent to Ms. Schout,
and opposing counsel did not have the opportunity to express any opinion on this
request.

/s/Stephen Casey

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing motion has
been served on Monday, August 24, 2015, on the following via electronic
transmission:

Marcie L. Schout
Quilling, Selander, Lownds,
Winslett, & Moser, P.C.
2001 Bryan Street, Suite 1800
Dallas, TX 75201
mschout@qslwm.com

/s/ Stephen Casey

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