ACCEPTED
06-14-00062-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
2/1/2015 6:53:54 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00062-CV
KRSTA LYNN GARDNER, § IN THE SIXTH COURT OF
FILED IN
INDEPENDENT EXECUTRIX OF § 6th COURT OF APPEALS
THE ESTATE OF LARRY RAY § TEXARKANA, TEXAS
TINER, § 2/4/2015 4:15:00 PM
Appellant, § APPEALS IN ANDDEBBIE
FOR AUTREY
§ Clerk
V. §
§
PENNY HEDDIN TINER § THE STATE OF TEXAS
MOTION TO EXTEND TIME TO FILE APPELLEE BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW PENNY HEDDIN TINER, by and through her attorney, Wm. Brandon
Baade, and makes this MOTION TO EXTEND TIME APPELLEE BRIEF:
1. The deadline for filing the Appellee’s Brief is January 28, 2015.
2. Appellee seeks and extension of four days (4) days until February 1, 2015 to file
Appellee’s Brief.
3. Facts relied on to reasonably explain the need for an extension:
Counsel for Appellee was granted a seven day extension because I was sick with
the flu. I anticipated getting better, I didn’t. Indeed I got worse and was placed
on antibiotics the very day the brief was due four days ago. I am still sick, but I
have got it done. I apologize to the court for being late by four days. It was not
intentional, nor intended to be dilatory or seek any advantage. I have an
immune system that is weakened for which I take injections three times a week,
and when I get sick it is difficult to overcome it. The brief is filed with this
motion.
Appellee has been granted one (2) extensions of time.
4. Appellee’s brief is being filed simultaneously with this Motion to Extend Time
to File Appelllee Brief.
WHEREFORE, Penny Heddin Tiner, by her attorney, Wm. Brandon Baade, requests
the court extend time to file Appellee’s Brief in this case.
RESPECTFULLY SUBMITTED,
Wm. Brandon Baade
522 N Broadway Ave
Tyler, TX 75702
Tel: (903) 526-5867
brandonbaadelaw@gmail.com
_______________________________
Wm. Brandon Baade
State Bar No. 00793189
Attorney for Appellee
CERTIFICATE OF CONFERENCE
I certify that I attempted to contact Lawrence Beason, Attorney for Appellant, in this case
at the phone number listed on the Appellant’s brief and the number was not in service.
_______________________________
Wm. Brandon Baade
State Bar No. 00793189
Attorney for Appellee
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the foregoing MOTION
TO EXTEND TIME TO FILE APPELEE’S BRIEF was served on all counsel of record by U.S.
Mail on February 1, 2015.
_______________________________
Wm. Brandon Baade
State Bar No. 00793189
Attorney for Appellee