in Re William B. Adams

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