ACCEPTED
03-15-00368-CV
6761658
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/2/2015 11:55:14 AM
JEFFREY D. KYLE
CLERK
NO. 03-15-00368-CV
IN THE COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
FOR THE THIRD SUPREME JUDICIAL DISTRICTAUSTIN, TEXAS
AT AUSTIN 9/2/2015 11:55:14 AM
JEFFREY D. KYLE
Clerk
LAURA PRESSLEY,
APPELLANT
vs.
GREGORIO "GREG" CASAR,
APPELLEE
SECOND MOTION TO EXTEND TIME FOR FILING APPELLANT'S
BRIEF
TO THE HONORABLE COURT OF APPEALS:
Now comes Laura Pressley, Appellant and pursuant to Tex.R.App.P.
10.5, moves this court to grant an extension of time to file Appellant's Brief,
and respectfully states:
1. The due date for Laura Pressley, Appellant's Brief is currently
September, 8 2015. The first extension motion was granted extending the
due date from August 18, 2015.The last Clerk's Record and the Reporter's
Record was filed on August 7, 2015. The trial court filed an order on
Appellant's request for additional Findings of Fact and Conclusions of Law
on August 13, 2015. Therefore the last filing of the Record was filed on
August 14, 2015.Tex. R App. P. 38.6(a).
2. Laura Pressley seeks an extension of time to file Appellant's
brief for 10 days from the current stated due date of September 8, 2015,
2015 or until September 18, 2015. The extension is needed because the
record in this case is voluminous and rather disorganized making preparing
the brief and appendix more time consuming than Appellant anticipated
when the first extension was requested. Appellant's attorney was out of the
office from August 22 until September 1, 2015 on a combination
family/business trip and was unable to work on the brief during that time(1 0
days of the time given in the first extension. In addition Appellant's attorney
has to get bills out as of the first of the month so he can pay the office
expenses with the client receipts and other professional commitments that
has and will further limit the time available for working on the brief
exclusively between the date hereof and September 8, 2015. The brief and
arguments are nearly finished but are currently over the word limit by over
1500 words and attorney for appellant needs additional time to lower the
word count to 15,000 words to comply with the rules of appellate procedure
while still presenting a complete discussion of the issues on appeal. In
addition to problems related to the length of the brief currently, the series
PRESSLEY MOTION TO EXTEND TIME Page 2
of judgments and other post judgment activities of the trial court , the length
and status of the record and the series of supplements and Appellant's
attorney's schedule , the brief cannot be properly and efficiently prepared
and filed before September 18, 2015.
3. Therefore, this Motion is in the interest of justice and orderly
presentation of the issues that need to be resolved in this appeal and not
for by reason of any procrastination or for delay.
4. Counsel for Laura Pressley has conferred with counsel for
Casar and Casar does not oppose this Motion to Extend Time to
September 18, 2015.
5. This is the second extension of time Laura Pressley has
presented to this Honorable Court for the filing of the Appellant's Brief.
PRAYER
For these reasons, Laura Pressley, Appellant requests that this court
enter an order extending the time for filing Appellant's Brief until September
18,2015
Laura Pressley also requests any other relief to which she may be
entitled.
Respectfully Submitted,
PRESSLEY MOTION TO EXTEND TIME Page3
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