ACCEPTED
02-17-00396-CV
SECOND COURT OF APPEALS
FORT WORTH, TEXAS
12/20/2017 12:02 PM
DEBRA SPISAK
CLERK
No. 02-17-00396-CV
FILED IN
2nd COURT OF APPEALS
In The FORT WORTH, TEXAS
SECOND DISTRICT COURT OF APPEALS
12/20/2017 12:02:41 PM
Fort Worth, Texas DEBRA SPISAK
Clerk
ALPINE INDUSTRIES, INC. and LANE THOMAS SHINOGLE,
Appellants,
v.
BENJAMIN WHITLOCK and BRIANNA WHITLOCK,
Appellees.
On Review from Cause No. 141-290670-17
In the 141st Judicial District Court, Tarrant County, Texas
Honorable John P. Chupp, Presiding Judge
APPELLANTS’ UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
Appellants Alpine Industries, Inc. and Lane Thomas Shinogle file this
Unopposed Motion for Extension of Time to File Brief and would respectfully show:
The Clerk’s Record and Reporter’s Record were filed in this accelerated
interlocutory appeal on December 12, 1017, and December 15, 2017, respectively.
Thus, the current deadline to file Appellants’ Brief is January 4, 2018. Appellants
request a fourteen-day extension of time to file their brief, which would make the brief
due on January 18, 2018. See Tex. R. App. 38.6(d). This is Appellants’ first request
for an extension of time to file their brief.
This short extension of time is necessary because of the work and travel
schedule for lead appellate counsel Wade Crosnoe, which will prevent him from
preparing the brief by the current deadline. Because of the upcoming holidays, there
are only twelve business days within which to complete Appellants’ Brief. During that
time, Mr. Crosnoe will be in Dallas on December 21-22, 2017, for a law firm meeting
and other firm business. And he will be out of the office visiting family from
December 23-26, 2017. Mr. Crosnoe has also been involved in drafting an Answer,
which is due today, in a lawsuit styled A. Bors Properties, LLC d/b/a Winfield
Property Management v. Certain Underwriters at Lloyd’s, London, et al., Case No.
4:17-cv-00671-GKF-FHM, in the U.S. District Court for the Northern District of
Oklahoma. The compressed briefing schedule in this accelerated appeal, the upcoming
holidays, and Mr. Crosnoe’s work and travel schedule do not leave enough time to
complete Appellants’ Brief by the current deadline. Accordingly, Appellants seek a
fourteen-day extension of time in order to complete their brief.
Appellees are not opposed to this motion.
For these reasons, Appellants respectfully request that the Court grant this
motion and extend the deadline to file their brief until January 18, 2018. Appellants
also request all other relief to which they are justly entitled.
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Respectfully submitted,
THOMPSON, COE, COUSINS & IRONS, L.L.P.
By: /s/ Wade C. Crosnoe
Wade C. Crosnoe
State Bar. No. 00783903
Thompson, Coe, Cousins and Irons, L.L.P.
701 Brazos, Suite 1500
Austin, Texas 78701
Telephone: (888) 708-8200
Telecopy: (512) 708-8777
E-mail: wcrosnoe@thompsoncoe.com
J. Richard Harmon
State Bar No. 09020700
Heather H. Sauter
State Bar No. 24042118
Cassie J. Dallas
State Bar No. 24074105
Plaza of the Americas
700 N. Pearl Street, Twenty-Fifth Floor
Dallas, Texas 75201-2832
Telephone: (214) 871-8200
Telecopy: (214) 871-8209
E-mail: rharmon@thompsoncoe.com
E-mail: hsauter@thompsoncoe.com
COUNSEL FOR APPELLANTS
ALPINE INDUSTRIES, INC. and LANE
THOMAS SHINOGLE
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CERTIFICATE OF CONFERENCE
I certify that I conferred with Appellees’ counsel, David Keltner, regarding this
motion, and that his clients are not opposed to this motion.
/s/ Wade C. Crosnoe
Wade C. Crosnoe
CERTIFICATE OF SERVICE
I certify that on December 20, 2017, this document was served on the following
counsel via the Court’s electronic filing system or by email:
Mike M. Basset
Charles Lindley Woods
Sadie A. Horner
The Basset Firm
Two Turtle Creek Village
3838 Oak Lawn, Suite 1600
Dallas, Texas 75219
Counsel for Appellees
Tim Dollar
Rachel D. Stahle
Dollar, Burns & Becker, L.C.
1100 Main Street, Suite 2600
Kansas City, Missouri 64105
Counsel for Appellees
David E. Keltner
State Bar No. 11239500
John T. Wilson IV
State Bar No. 24033344
Kelly Hart & Hallman LLP
201 Main Street, Suite 2500
Fort Worth, Texas 76102
Counsel for Appellees
/s/ Wade C. Crosnoe
Wade C. Crosnoe
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