ACCEPTED
05-15-00910-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
9/24/2015 1:50:42 PM
LISA MATZ
CLERK
No. 05-15-00910-CV
FILED IN
5th COURT OF APPEALS
In The DALLAS, TEXAS
COURT OF APPEALS
9/24/2015 1:50:42 PM
LISA MATZ
Clerk
FIFTH DISTRICT OF TEXAS
Dallas, Texas
David Cole, Independent Administrator of the
Estate of Kathryn Cole, Deceased
Appellant,
v.
Amica Mutual Insurance Company,
Appellee.
On Appeal from Cause No. DC-15-02618-D
In the 95th Judicial District Court of Dallas County, Texas
Honorable Ken Molberg, Presiding Judge
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE DALLAS COURT OF APPEALS:
Appellant David Cole Independent Administrator of the Estate of Kathryn Cole,
Deceased (“Appellant”), represented by Jo Allison Stasney of Thompson, Coe, Cousins
& Irons, L.L.P. (email address: jstasney@thompsoncoe.com) files this Unopposed
Motion for Extension of Time to File Appellant’s Brief and respectfully shows:
1. The current deadline to file Appellant’s Brief is September 30, 2015.
Appellant’s Unopposed Motion for Extension of Time to File Appellant’s Brief Page 1
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2. Appellant seeks a 15-day extension of time to file its Brief. See Tex.
R. App. P. 38.6(d); 10.5 (b). Accordingly, Appellant seeks an extended deadline to
October 15, 2015.
3. This is Appellant’s first request for an extension of time to file its
Brief.
4. This extension of time is necessary due to the schedule of Appellant’s
lead appellate counsel, Jody Stasney. Specifically, her schedule prevents her from
preparing the Brief by the current deadline. Matters over the last few weeks being
handled by Ms. Stasney required immediate attention, including a federal court
removal with out-of-the-ordinary legal issues and finalizing settlements in a
seven-party insurance company lawsuit pending in federal court in Arizona
pursuant to the court’s September 2, 2015 order imposing a September 30, 2015
deadline, along with finalizing the settlement of a related bad faith action
pending in state court in Arizona. Additionally, Ms. Stasney has been attending
to personal matters involving the sale of her mother’s house in Fort Worth.
5. Counsel for Appellant has personally communicated with counsel for
Appellee regarding this motion, and Appellee is not opposed to this motion and
the relief sought.
For these reasons, Appellant respectfully requests that the Court grant this
motion and extend the deadline to file Appellant’s Brief until October 15, 2015,
and grant any other relief to which it is justly entitled.
Appellant’s Unopposed Motion for Extension of Time to File Appellant’s Brief Page 2
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Respectfully submitted,
___/s/ Jo Allison Stasney___________
Jo Allison Stasney
State Bar No. 19080280
THOMPSON, COE, COUSINS & IRONS, L.L.P.
Plaza of the Americas
700 N. Pearl Street, Twenty-Fifth Floor
Dallas, TX 75201-2832
Telephone: (214) 871-8200
Telecopy: (214) 871-8209
E-Mail: jstasney@thompsoncoe.com
Wade C. Crosnoe
State Bar No. 00783903
THOMPSON, COE, COUSINS & IRONS, L.L.P.
701 Brazos, Suite 1500
Austin, Texas 78701
Telephone: (512) 703-5078
Telecopy: (512) 708-8777
E-Mail: wcrosnoe@thompsoncoe.com
COUNSEL FOR DAVID COLE, INDEPENDENT
ADMINISTRATOR OF THE ESTATE OF
KATHRYN COLE, DECEASED
CERTIFICATE OF SERVICE
This is to certify that on the 24th day of September, 2015, a copy of the
foregoing was sent via electronic notice and/or certified mail, return receipt
requested to Appellee’s counsel as follows:
Neil A. Bickley
Attorney at Law
301 S. Sherman, Suite 103
Richardson, TX 75081
s/ Jo Allison Stasney_______________
Jo Allison Stasney
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