Anna Marie Inman v. Equable Ascent Financial, LLC

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