ACCEPTED
07-14-00393-CV
SEVENTH COURT OF APPEALS
AMARILLO, TEXAS
7/29/2015 11:56:57 AM
Vivian Long, Clerk
NO. 07-14-00393-CV
IN THE COURT OF APPEALS
FILED IN
FOR THE SEVENTH DISTRICT OF TEXAS AT AMARILLO
7th COURT OF APPEALS
AMARILLO, TEXAS
MAGDALENA MCMORDIE, 7/29/2015 11:56:57 AM
in her
capacity as Beneficiary and Co-Trustee VIVIAN LONG
CLERK
of the Hobart B. McMordie, II Asset Management Trust
Appellant/Cross Appellee,
v.
CHARLES HARRIS MCMORDIE,
in his capacity as Co-Trustee
of the Hobart B. McMordie, II Asset Management Trust
Appellee/Cross-Appellant.
FROM THE 251ST DISTRICT COURT
RANDALL COUNTY, TEXAS
THE HONORABLE ANA ESTEVEZ, JUDGE PRESIDING
CAUSE NO. 66,482-C
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE MOTION FOR REHEARING
TO THE HONORABLE COURT OF APPEALS:
Charles Harris McMordie (“Charles”) files this Unopposed Motion for
Extension of Time to File Motion for Rehearing, and in support thereof shows the
Court the following:
I.
DUE DATE
Charles’ Motion for Rehearing is currently due on August 8, 2015. Charles
seeks an additional twenty (20) days, until August 28, 2015, to file his Motion for
Rehearing.
II.
REASONS FOR EXTENSION OF TIME
Charles’ counsel is involved in a number of other matters with deadlines and
settings that will interfere with Charles’ ability to timely file his Motion for
Rehearing.
III.
EXTENSION SOUGHT IN THE INTEREST OF JUSTICE
The extension sought is not for the purpose of delay, but rather, is sought in
the interest of justice and to allow Charles to fully brief issues to the Court.
IV.
APPELLANT/CROSS-APPELLEE AGREES TO THIS REQUEST
Counsel for Appellant/Cross-Appellee, Slater C. Elza, does not oppose this
motion for extension of time.
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING Page 1
V.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Charles Harris McMordie prays
that the Court grant an extension of time of twenty (20) days, until August 28, 2015,
to file his Motion for Rehearing.
Respectfully submitted,
/s/ David J. Drez III
David J. Drez III
State Bar No. 24007127
david.drez@wickphillips.com
Meredith L. Perry
State Bar No. 24075622
meredith.perry@wickphillips.com
WICK PHILLIPS GOULD & MARTIN
LLP
100 Throckmorton Street, Suite 550
Fort Worth, Texas 76102
Telephone: 817.332.7788
Telecopier: 817.332.7789
Scott W. Sherwood
State Bar No. 18255250
Sherwood and Sherwood
303 Euclid Street
Panhandle, Texas 79068
Telephone: 806.537.3591
Telecopier: 806.537.3592
ATTORNEYS FOR APPELLEE/
CROSS-APPELLANT CHARLES
HARRIS MCMORDIE
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING Page 2
CERTIFICATE OF CONFERENCE
On July 28, 2015, I contacted counsel for Appellant/Cross-Appellee, Slater C.
Elza, and Appellant/Cross-Appellee is not opposed to this Motion.
/s/ David J. Drez III
David J. Drez III
CERTIFICATE OF SERVICE
A true copy of the foregoing document was served on the following counsel
of record via electronic filing, on this 29th day of July, 2015:
Slater C. Elza
Jennie C. Knapp
UNDERWOOD LAW FIRM, P.C.
P.O. Box 9158
Amarillo, Texas 79105
/s/ David J. Drez III
David J. Drez III
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING Page 3