FILED
15-0358
8/19/2015 4:04:11 PM
tex-6569047
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK
NO. 15-0358
IN THE SUPREME COURT
OF TEXAS
IN RE: WILLIAM B. ADAMS,
Relator,
HON. GENA SLAUGHTER
191ST JUDICIAL DISTRICT COURT
DALLAS COUNTY, TEXAS,
Respondent,
CTK PROPERTIES, LLC AND CHRISTOPHER KLEE,
Real Parties in Interest.
Original Proceeding from the Fifth District Court of Appeals, Dallas Texas
Appeal No. 05-15-00536-CV and
191st District Court, Dallas County, Texas
Trial Court No. DC-11-08224
REAL PARTIES IN INTEREST'S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSE TO MANDAMUS
BYRON K. HENRY
Texas Bar No. 24008909
bhenry@cowlesthompson.com
COWLES & THOMPSON, P.C.
901 Main Street, Suite 3900
Dallas, TX 75202
(214) 672-2156
(214) 672-2356 (FAX)
ATTORNEYS FOR REAL
PARTIES IN INTEREST
1511889.1 1
TO THE HONORABLE SUPREME COURT OF TEXAS:
Real Parties in Interest, CTK Properties, LLC and Christopher Klee, file this
Motion for Extension of Time to File Response to Mandamus, and in support the Court
the following:
1. The deadline for filing a Response is Wednesday, August 19, 2015.
2. Real Parties in Interest seek a brief five-day extension of time to file its Response,
up to and including, Monday, August 24, 2015.
3. Real Parties in Interest require an extension of time to file the Response because
Lead Appellate Counsel, Byron K. Henry, was involved in other matters earlier in
the month which precluded him from working on the Response. Most recently,
Mr. Henry had a personal family matter that required him to be out of the office
and unable to complete the response by the deadline. He has returned, however,
and will complete file the response by the requested deadline.
4. There has been one prior extension of time for filing this Response.
5. Opposing counsel is not opposed to the motion.
WHEREFORE, PREMISES CONSIDERED, Real Parties in Interest, CTK
Properties, LLC and Christopher Klee respectfully request that the Court grant their
motion to extend time to file their response such that the response be due on or before
Monday, August 24, 2015, and grant Real Parties in Interest such further and additional
relief as the Court deems appropriate.
1511889.1 2
Respectfully submitted,
By: ___________________________
BYRON K. HENRY
Texas Bar No. 24008909
bhenry@cowlesthompson.com
COWLES & THOMPSON, P.C.
901 Main Street, Suite 3900
Dallas, TX 75202
(214) 672-2156 (Tel)
(214) 672-2356 (Fax)
ATTORNEYS FOR REAL
PARTIES IN INTEREST
CERTIFICATE OF CONFERENCE
The undersigned counsel certifies that he contacted lead counsel for Relator
regarding this motion and he is not opposed to the relief requested in this motion.
______________________________
Byron K. Henry
CERTIFICATE OF SERVICE
The undersigned certifies that on the August 19, 2015, a true and correct copy of
this motion was delivered via Electronic Service to the counsel of record listed below.
Marshal W. Dooley
Dooley & Associates, P.C.
14228 Midway Road, Suite 214
Dallas, TX 75244
Email: mdooley@dooley-law.com
______________________________
Byron K. Henry
1511889.1 3