05/26/2021 05:18 4062932435 ANN GERMAN PA CiE
05/27/2021
Ann C. German
P.O. Box 1530
ir'Nil AIL Case Number: DA 21-0006
Libby, MT 59923
(406)293-4191 FILED
facsimile: (406)293-2435
anngerman@lclink.com MAY 2 7 2021
Bowen
Clerk of Greenwood
Attorney for Appcllant StateSupreme
of Court
Montana
IN THE SUPREME COURT OF THE STATE OF MONTANA
Supreme Court Cause No. DA 21-0006
In Re The Marriage Of:
JOIINETTE GAY JONES WATKINS, )
)
Appellant, )
)
vs. ) MOTION FOR EXTENSION OF TIME
CHARLES EDWARD WATKINS,
)
Appellee.
Appellant, Johnette Gay Jones Watkins, by her attorney for record, moves the Court,
pursuant to Rule 26(2), M.R.App.P., for an cxtension of five(5)days from the current due dale
of June 2, 2021 to June 7,2021, in which to file and serve Appellant's opening brief on appeal.
The opening brief was first due on March 12, 2021, and an extension was granted by the Clerk. of
the Supreme Court to allow filing by April 12, 2021. A fourth extension was granted to allow
filing by June 2, 2021. Since that extension was granted, the undersigned has been working
diligently on this matter in order to cornplete and file the opening brief, but needs additional time
in which to do so and to ensure that thc brief is received and filed in time. As stated in the
Affidavit of Ann C. German filed herewith, the opening brief of Appellant will be filed and
served no later than June 7, 2021 and no further extensions will be requested.
MOTION FOR EXTENSION OF TIME
05/26/2021 05:18 4062932435 ANN GERMAN PAGE 02A6
I have contacted opposing counsel, but was unable to mach her, as set forth in the
Affidavit ofAnn German Bled herewith. It is not expected that opposing counsel would object
to a five day extension as requested.
DATED this 26th day of May,2021.
C. GERMAN,Attorney for Appellant
CERTIFICATE OF SERVICE
I certify that, on May 26,2021,I have filed by facsimile transmission the foregoing
Motion and accompanying Affidavit of Ann C. German with the Clerk ofthe Montana Supreme
Court,and that I have mailed a copy thereof,first class mail, postage prepaid, to the attomey for
Appellee, Amy N. Guth,408 Main Avenue,Libby, MT 59923.
DATED this 26th day of May,2021.
C. GERMAN,Attorney for Appellant
MOTION FOR EXTENSION OF TIME
05/26/2021 05:10 4062932435 ANN GERMAN PAGE 04/06
Ann C. German
P.O. Box 1530 . RLED
Libby,MT 59923
(406)293-4191 MAY 2 7 2021
facsimile: (406)293-2435 Bowen Greenwood
anngerman@lclink.com aerk of Suprer-ne Court
State of Mnntana
Attorney for Appellant
IN THE SUPREME COURT OF THE STATE OF MONTANA
Supremc Court Cause No.DA 21-0006
In Re The Marriage Of:
JOHNETTE GAY JONES WATKINS,
AFFIDAVIT OF COUNSEL
Appellant,
vs.
CHARLES.EDWARD WATKINS,
• Appellee.
I, ANN C. GERMAN,declare under the penalty of perjury and under the laws ofthe state
of Montana that the following is true and correct to the best of my knowledge:
1. I am the attomey foi the Appellant herein, and I make this affidavit in support of
appellant's Motion for Extension of Time dated May 26,2021.
2. The opening brief was grit due on March 12,2021,and an extension was granted by
the Clerk ofthe Supreme Court to allow filing by April 12,2021. A fourth extension was
granted by the COurt to allow filing by June 2, 2021.
3. Appellant is re'questiiig'an 6aenision offive(5)days for filing and serving her opening
brief, that is, until hie 7;2021. The grounds for this request are that, due to the Memorial Day
Holiday on May 31,2021,and the recent delays in the mail,the undersigned fears that the
opening brief may not be received and filed by June 2,2021. In order to comply with this
Coures Order for filing and service, the undersigned believes it necessary to request the
additional five days V.) ensure that the- oPening-briefis -received and filed on time. ,
AFFIDAVIT OF COUNSEL IN SUPPORT OF monoN FOR EXTENSION OF TIME
05/26/2021 05:18 4062932435 ANN GERMAN PAGE 05/06
4. I declare that I, as appellant's attorney, have exercised diligence and have substantial
need for the extension and I further declare that the brief will be filed within the time requested,
i.e., no later than June 7,2021. Since the last extension was granted,the undersigned has been
working diligently on this matter in order to complete and file the opening brief, but needs
additional time to ensure that tbe briefis received and filed on time. No further requests for
extensions will be made.
5. The undersigned attempted twice to contact Amy N. Guth, attorney for Appellee,
before completing and transmitting this Motion, but was unable to reacb her before the
undersigned had to leave her office to travel out oftown for a previously scheduled appointment.
It is not expected that she will object to the allowance ofan additional five(5)days for the
reasons set forth supra.
I, Ann C. German, declare under penalty of perjury and under the laws ofthe state of
Montana that the foregoing is true and correct to the best of my knowledge.
Dated this day of MaY,202i.
Ann C German,Attorneyfor Appellant
AFFIDAVIT OF COUNSEL IN SUPPORT OF MOTION FOR EXTENSION OF TIME
2