Brian McMullen v. Tina McMullen

ACCEPTED 03-15-00545-CV 13888552 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/18/2016 7:18:59 PM JEFFREY D. KYLE CLERK NO.03-15-00545-CV BRIAN MCMULLEN § FILEDININ THE 3rd COURT OF APPEALS § AUSTIN, TEXAS VS. § THIRD COURT 11/18/2016 7:18:59 PM § JEFFREY D. KYLE TINA MCMULLEN § Clerk OF APPEALS MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF TO THE HONORABLE JUSTICES OF THE COURT: COMES NOW TINA MCMULLEN,Appellee in this matter and moves this Court to grant an extension oftime to file Appellee's brief, pursuant to Rule 38.6(d), in compliance with Rule 10.5(b)ofthe Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 146 Judicial District Court ofBell County, Texas. 2. The case below was styled In the Matter ofthe Marriage ofBrian McMullen and Tina McMullen, and was numbered 234,417-B. 3. Notice of appeal was given on August 28,2015. 4. The Clerk's record was filed on October 1, 2015, and the Reporter's record was filed on September 22,2015. 5. Appellant's brief was due on November 2,2015, granted an extension to February 1,2016,and granted an extension to May 2,2016. 6. Appellant's brief was filed with this Court and accepted on May 17, 2016. 7. Appellee's brief was due on June 16, 2016. 8. Appellee filed a Motion to Extend on June 16,2016, and the Court granted an extension with the brief due on September 14,2016. 9. Appellee filed Appellee's Briefon October 21,2016, but had not requested a second extension until this motion. 10. Appellee requests an extension to November 22,2016, and asks that Appellee's Brief already received by the Court on October 21,2016,be accepted by the Court ifthe Court grants this request for extension. 11. Appellee relies on the following facts as good cause for the requested extension: Counsel for Appellee has already prepared and submitted Appellee's Brief. Ifthis Motion is granted. Appellee's Brief has already been received by this Court. No additional time will be necessary. WHEREFORE,Appellee prays that this Court grant this Motion to Extend Time to File Appellee's Brief. Respectfully Submitted, 'Allison E.^czek Attorney for Appellee State Bar No.: 24043766 kuczeklaw@hotmail.com PO Box 3299, Marker Heights, Texas 76548 Phone: 254-220-4141 Fax: 254-220-4140 Certificate of Service I certify that a true copy of the above was served on each attorney of record or party in accordance with the Texas Rules of Civil Procedure on November 18, 2016. Appellant was served by facsimile at 254-770-0883. s, XISON E. KUCZEK 'Attorney for Appellee Certificate of Conference I certify that reasonable effort has been made to resolve this matter without the necessity of filing for an Extension. On November 18, 2016, I conferenced with opposing counsel's office, and he is in agreement with the requested extension. ALLISON E.KUCZEK, Attorney for Appellee