Marta Carrejo Martinez v. Janet D. Mangrum

ACCEPTED
02-17-00235-CV
SECOND COURT OF APPEALS
FORT WORTH, TEXAS
12/20/2017 9:23 AM
DEBRA SPISAK
CLERK

NO.02-17-00235-CV

MARTA CARREJO MARTINEZ § IN THE SECOND DISTRICT
§ FILED IN
2nd COURT OF APPEALS
Appellant, § FORT WORTH, TEXAS
§ 12/20/2017 9:23:49 AM
v. § COURT OF APPEALS
DEBRA SPISAK
§ Clerk
JANET MANGRUM §
§
Appellee. § AT FORT WORTH, TEXAS

APPELLEE'S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME

TO THE HONORABLE CLERK AND JUSTICES:

COMES NOW Appellee Janet D. Mangrum and files this motion seeking an extension

of time to file the Appellee's Brief and for good cause would show the following:

1. This case is on appeal from the 96th District Court of Tarrant County, Texas.

2. The case in the trial court was styled Janet Mangrum v. Marta Carrejo Martinez,

Cause No. 096-263989-13.

3. Appellant filed her Brief on November 29,2017 after one thirty (30) day

extension and one sixty (60) day extension.

4. Appellee's Brief is currently due December 29,2017.

5. No previous request for extension of time has been made by or granted to the

Appellee.

6. Appellee requests a thirty (30) day extension of time to file the Appellee's Brief.

7. In support of this Motion and as good cause, Appellee's counsel shows that he will

be unable to complete the Brief in this case before the due date because of parental responsibilities

during the holidays. Appellee's counsel will be out of the office taking care of his special needs

son during the holidays, and will be unable to work on the Brief.

Appellee's First Unopposed Motion For Extension Of Time Page 1
 WHEREFORE. Appellee respectfully requests that this Court grant this Motion and extend

the due date for Appellee's Brief by thirty (30) days until January 29,2018.

~~:ed'
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Texas Bar Card No. 03657020
LAW OFFICES OF NEAL S. CALLAWAY
1200 Summit Ave., Suite 720
Fort Worth TX 76102
817/332-2076; FAX 817/877-5661
ATTORNEY FOR APPELLEE
callawaylaw@sbcglobal.net

CERTIFICATE OF CONFERENCE

This is to certify that on the 15th day of December, 2017, Leigh W. Davis, attorney for Appellant,
stated that he did not oppose this Motion and its requested relief.

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CERTIFICATE OF SERVICE

This is to certify that on the 20th day of December, 2017, a copy of the foregoing was served by
electronic service to the following:

(Mr.) Leigh W. Davis
1901 Central Drive, Suite 708 LB 57
Bedford, TX 76021
leighwdavis@gmail.com

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Appellee's First Unopposed Motion For Extension Of Time Page 2