Richard Chalker v. Nationstar Mortgage, LLC

FILED IN 2nd COURT OF APPEALS FORT WORTH, TEXAS 12/19/2017 3:01:45 PM DEBRA SPISAK Clerk EXHIBIT A COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH CASE NO. 02-17-00250-CV RICHARD CHALKER, APPELLANT V. NATIONSTAR MORTGAGE, LLC, APPELLEE FROM THE 393RD illDICIAL DISTRICT COURT OF DENTON COUNTY TRIAL COURT NO. 15-04402-393 RULE 11 AGREEMENT REGARDING APPELLEE NATIONSTAR MORTGAGE, LLC'S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF APPELLEE NATIONSTAR MORTGAGE LLC ("Nationstar"), by and through its attorney of record, and APPELLANT RICHARD CHALKER ("Mr. Chalker"), by and through his attorney of record, ( collectively, "the Parties") enter this Rule 11 agreement to memorialize their agreement incident to the lawsuit, self-styled as above. The Parties agree to the following: 1. The Parties acknowledge that this is a binding Rule 11 agreement under the provisions of Rule 11 ofthe Texas Rules ofCivil Procedure. 2. Appellant Chalker agrees to Appellee Nationstar's request for a thirty (30) day extension of Nationstar's current due date of January 8, 2018 for filing its appellee brief in the above­ captioned action. 3. The Parties agree and acknowledge that Appellee needs additional time to include thirty (30) days beyond January 8, 2018 to February 7, 2018, to evaluate and consider Appellant's pending settlement proposals for a possible resolution of this appeal. Therefore, Appellant Chalker does not oppose Nationstar's motion for thirty (30) day extension ofNationstar's due date for filing its briefto February 7, 2018. RULE 11 AGREEMENT RE: APPELLEE'S UNOPPOSED MOTION FOR EXTENSION OF BRIEF DUE DATE Cause No. 02-17-00250-CV; Richard Chalker v. Nationstar Mortgage, LLC Page I 4. The Parties further agree that except as expressly stated herein, this Rule 11 agreement does not place limitation on the claims, defenses, actions, positions or legal rights of the parties in litigating the appeal, and the Parties agree that efforts to resolve this matter, including but not limited to settlement discussions, meetings, and negotiations, shall continue unabated. Date: December 18, 2017 Respectfully submitted, /s/ Elizabeth Chandler Elizabeth Chandler, SBN: 24097484 echandler@mcguirewoods.com McGUIREW00DS LLP 2000 McKinney Avenue, Suite 1400 Dallas, Texas 75201 Telephone: 214.932.6400 Facsimile: 214.932.6499 ATTORNEY FOR APPELLEE NATIONSTAR MORTGAGE LLC Mark Lieberman, SBN: 12332520 Mic358@hotmail.com LAW OFFICE OF MARK LIEBERMAN 1704 Pine Hills Rd. Corinth, Texas 76219 Telephone: 817.305.3772 Facsimile: 469.385.8823 ATTORNEY FOR APPELLANT RULE 11 AGREEMENT RE: APPELLEE'S UNOPPOSED MOTION FOR EXTENSION OF BRIEF DUE DATE Cause No. 02-17-00250-CV; Richard Chalker v. Nationstar Mortgage, LLC Page 2