ACCEPTED
06-14-00079-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/11/2015 8:34:25 AM
DEBBIE AUTREY
CLERK
Cause No.: 06-14-00079-CV
IN THE COURT OF APPEALS
SIXTH DISTRICT OF TEXAS AT TEXARAKANA FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
MONDEE STRACENER, Appellant
3/11/2015 4:28:00 PM
DEBBIE AUTREY
v. Clerk
DOUG STRACENER, BERNICE L. STRACENER AND
JOEY KEITH STRACENER, Appellees
APPELLEES' MOTION FOR ADDITIONAL TIME TO FILE APPELLEES' BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
Come now, Doug Stracener, Bernice L. Stracener, and Joey Keith Stracener,
hereinafter referred to as Appellees, and file this Motion for Additional Time to File
Appellees' Brief.
I.
The deadline for filing Appellees' Brief is March 13, 2015.
II.
Appellees have been unable to file Appellees' Brief for the filing reasons , for which
constitute good cause for the extension of time:
1. The undersigned attorney has been required to submit a brief to the 2761h
Judicial District Court of Camp County, Texas, in Cause No . No. CV-13-2156, which was
due February 13, 2015.
2. The undersigned attorney has prepared for a trial in the County Court at Law
No. 2 of Dallas County, Texas , in Cause No. CC-13-00417-B, which was scheduled for the
Appellees' Motion fo r Additional Time to File Appellees' Brief
Page 1
week of February 16, 2015, but canceled after time had already been spent preparing for
the trial;
3. The undersigned attorney had a trial in the 2761h Judicial District Court of
Camp County, Texas, in Cause No. No. CV-14-2384, on February 27 , 2015;
4. The undersigned is further has scheduled depositions in Cause No. 2014-
1762-5, a case pending in District Court of Mclennan County, that require him to travel
to Waco on March 10, 2015;
5. The undersigned is further scheduled for hearing on a Motion for Summary
Judgment as well as various pretrial motions in the 76th/276th Judicial District of Camp
County, Texas, in Cause No. No. CV-12-2016; and
6. The undersigned would further show that he has conferred with Mr. Robert
M. Minton, attorney for Appellant, and Mr. Minton is not opposed to this Motion .
The undersigned , that in order to serve the interests of justice for all of is potentially
effected clients, respectfully requests the Court to extend the time for filing Appellees' Brief
to the 121h day of April, 2015. This request is not made for the purpose of delay, but so that
the undersigned may adequately serve the interests of the legal profession in seeing to it
that his clients are adequately advised, represented, and their work completed on time, as
well as to handle the appeal of this proceeding .
Ill.
This extension of time is sought so that justice may be done and not for the
pu rposes of delay.
Appellees' Motion for Additional Time to File Appellees' Brief
Page 2
IV.
Granting this request for an extension of time to file will not delay the business of
the Court.
WHEREFORE PREMISES CONSIDERED, Appellees request the Court to grant an
extension of time until April 12, 2015, to file Appe llees' Brief.
Respectfully submitted:
GRIFFITH & GRIFFITH LAW FIRM , P.C.
404 North Titus
P.O. Box 864
Gilmer, Texas 75644-0864
Tel: (903) 843-5005
Fax: (903) 843-5392
E-Mail: davidg@griffithlawfirm .com
Attorney for Appellees
Doug Stracener, Bernice L. Stracener and
Joey Keith Stracener
CERTIFICATE OF SERVICE
~
I certify that on March / '!/ , 2015, a true and correct copy of Appellees'
Motion for Additional Time to File Appellees' Brief was served on Robert M. Minton via
email to mintonbrown@suddenlinkmail.c~ ~
_..,David B .~Griffith
Appellees' Motion for Additional T ime to File Appellees' Brief
Page 3