ACCEPTED
03-14-00341-CV
3986001
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/2/2015 2:20:55 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00341-CV
_____________________________________________________________
FILED IN
3rd COURT OF APPEALS
In the Third Court of Appeals AUSTIN, TEXAS
_____________________________________________________________
2/2/2015 2:20:55 PM
JEFFREY D. KYLE
James Richardson Clerk
Appellant,
v.
Maria Torres, et al.
Appellees
_____________________________________________________________
Appeal from Cause No. C-1-CV-13-009448
County Court No. 2, Travis County, Texas
Hon. David Phillips
_____________________________________________________________
APPELLANT’S THIRD UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S REPLY BRIEF
_____________________________________________________________
King Law Group, PLLC
Mary Ellen King
Texas State Bar No. 24067219
Richard C. King Jr.
Texas State Bar No. 24007491
28515 Ranch Road 12
Dripping Springs, Texas 78620
512.263.8212 (phone)
512.900.2918 (fax)
Counsel for Appellant James Richardson
Comes now Appellant James Richardson (“Richardson”), pursuant to Texas
Rules of Civil Procedure 10/5(b)(1), and requests additional time to file his Reply
Brief. In support of this motion, Richardson states as follows:
1. The Notice of Appeal of this matter was filed in the 3rd Court of
Appeals (the “Court”) on May 28, 2014;
2. Appellant filed the Docketing Statement with the Court on June 6,
2014;
3. Appellant immediately requested the Report’s Record and the Clerk’s
Record from County Court No. 2 in Travis Count, Texas;
4. The Reporter’s Record and the Supplemental Reporter’s Record were
filed with the Court on June 11, 2014, and June 18, 2014, respectively;
5. The Clerk’s Record was filed with the Court on June 24, 2014;
6. The Record was checked out on June 30, 2104;
7. The District Clerk’s Supplemental Record was filed on September 2,
2014
8. The Appellant’s Brief, oral argument not requested, was filed on
September 26, 2014;
9. The Appellee’s Brief, oral argument not requested, was filed December
18, 2014’
10. The Court calendared the due date of Appellant’s Rely Brief for January
7, 2015;
11. Appellant requested and was granted an additional fifteen days to file
Appellant’s Reply Brief, up to and including January 23, 2014;
12. Appellant requested and was granted another 15-day extension to file
its rely brief, up to and including February 6, 2015;
13. This third requested extension is unopposed and is necessary due to
medical issues concerning Appellant’s counsel;
14. Lead counsel had a due date of February 9, 2015 but had unexpected
complications over the past weekend requiring baby to be taken via C-section;
15. Co-lead counsel is the husband of lead counsel;
16. Appellant counsel suffered a serious physical injury last week that
required surgery;
17. The extension requested herein is not intended to cause undue delay,
prejudice or unnecessary hardship on any party; and
18. Appellant has previously requested and was granted two 15-day
extensions to file its rely brief.
WHEREFORE, Appellant requests an additional 21 days, up to and including
February 27, 2015, to file Appellant’s Reply Brief.
Dated this 30th day of January 2015.
Respectfully submitted
KING LAW GROUP, PLLC
/.s/ Mary Ellen King
Mary Ellen King
Texas State Bar No. 24067219
meking@kinglitigationgroup.com
Richard C. King Jr.
Texas State Bar No. 24007491
rking@kinglitigationgroup.com
28515 Ranch Road 12
Dripping Springs, Texas 78620
512.263.8212 (phone)
512.900.2918
Counsel for Appellant, James Richardson
CERTIFICATE OF CONFERENCE
Counsel for Appellant hereby represents to the Court that we have conferred
with counsel for Appellee regarding the extension requested and he has no objection
to the requested extension.
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the following instrument has
been served to opposing counsel via facsimile on this the 30th day of January, 2015.
Jesus Tirrez
The Law Office of Jesus Tirrez & Associates
1301 South IH-35, Suite 307
Austin, Texas 78741
Phone (512) 326.1330
Facsimile (512) 275.0075
tirrez@mail.com
Attorneys for Appellees, Maria Torres, et al
/.s/ Mary Ellen King
Mary Ellen King