ACCEPTED
12-15-00220-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
12/16/2015 3:35:32 PM
Pam Estes
CLERK
NO. 12-15-00220-CV
FILED IN
12th COURT OF APPEALS
IN THE TYLER, TEXAS
12/16/2015 3:35:32 PM
TWELFTH COURT OF APPEALS PAM ESTES
Clerk
TYLER, TEXAS
ANNA INMAN
Appellant,
v.
EQUABLE ASCENT FINANCIAL, LLC.
Appellee.
On Appeal from the 392nd Judicial District Court of Henderson County, Texas,
EQUABLE ASCENT FINANCIAL, LLC v. Anna Inman, Cause No. 2011B-1051
UNOPPOSED MOTION TO EXTEND TIME
TO FILE APPELLEE'S BRIEF
TO THE HONORABLE FIRST COURT OF APPEALS:
Appellee EQUABLE ASCENT FINANCIAL, LLC asks the Court to extend
the time to file its Appellee's Brief and will show the Court as follows:
BACKGROUND
Appellee's Brief is due on December 18, 2015. Due to the reasons stated
below, Appellee requests additional time to file its Brief.
ARGUMENT & AUTHORITIES
Appellee requests an additional thirty (30) days to file its Brief, extending the
deadline until January 18, 2016. Appellee needs additional time to file its Brief.
Counsel for Appellee has taken over the handling of cases all over the State of Texas
that were previously handled by Anh Regent, a Houston attorney who filed
bankruptcy proceedings and closed his practice. This process has been chaotic and
difficult due to hearings being set on a daily basis throughout the state with very
little notice being provided to Appellee's clients. Counsel for Appellee is the lead
counsel in these cases and this out of the ordinary scenario has delayed his ability to
complete Appellee's brief.
Appellee requests a short extension of time to file Appellee's brief in order to
be able to complete the preparation of a brief that is concise and aids the Court in
analyzing this appeal.
No prior extensions of time have been granted to extend the deadline to file
Appellee's Brief
Appellee therefore requests an additional thirty (30) days to file its Brief.
This Motion is requested in the interest of justice and is not brought with the intent to
delay the proceedings of this matter.
PRAYER
For these reasons, Appellee asks the Court to grant an extension of time to file
Appellee's Brief until January 18, 2016.
Respectfully submitted,
CI.,_
Dan G. Young
State Bar No. 22177250
JENKINS, WAGNON & YOUNG, P.C.
P.O. Box 420
Lubbock, Texas 79408
(806) 796-7351
Fax: (806) 771-8755
ATTORNEYS FOR APPELLEE
VERIFICATION
STATE OF TEXAS
COUNTY OF LUBBOCK
Before me, the undersigned Notary Public, on this day personally appeared
Dan G. Young, who being by me duly sworn on his oath, deposed and said that he is
an attorney for Appellee in the above-entitled and numbered case; that he has read
the above and foregoing Motion to Extend Time to File Appellee's Brief; and that
every statement contained therein is within his personal knowledge and is true and
correct.
Dan G. Young
SUBSCRIBED AND SWORN TO BEFORE ME ON THIS N. day of
December, 2015.
04.2.1144,
JAMIE L CARLSON
4%
.!:.7 .s Notary Public. State of Texas
S.V..Pik.:4 Comm. Expires 07-20-2016
Nolary Ib 120351111
N I GARY PUBLIC,
hnm
STATE OF TEXAS
CERTIFICATE OF CONFERENCE
On December 16, 2015, my office communicated with Richard Tomlinson
regarding the filing of this Motion and he indicated that he was unopposed to such.
Dan G. Young
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the foregoing Motion
to Extend has been served via the Court's Electronic Filing System on this 16th day
of December, 2015 on the following:
Richard Tomlinson
Lone Star Legal Aid
1415 Fannin Street
Houston, TX 77002
Dan G. Young