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' -~ 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. ~ ..•. 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 Ne~ ~ Appellee's First Unopposed Motion For Extension Of Time Page 2