ACCEPTED
06-15-00024-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/11/2015 1:21:08 PM
DEBBIE AUTREY
CLERK
No. 06-15-00024-CV
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IN THE COURT OF APPEALS FILED IN
6th COURT OF APPEALS
FOR THE SIXTH DISTRICT OF TEXAS AT TEXARKANA
TEXARKANA, TEXAS
—————————————————————————————— 11/12/2015 8:42:00 AM
MONTY CLAY, ET AL. DEBBIE AUTREY
Clerk
Appellant
v.
AIG AEROSPACE INSURANCE SERVICES, INC., ET AL.
Appellee
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On Appeal from the 402nd District Court of Wood County
G. Timothy Boswell, Judge Presiding
——————————————————————————————
APPELLEE AIG AEROSPACE INSURANCE SERVICES, INC.’S
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLEE’S BRIEF
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Appellee AIG Aerospace Insurance Services, Inc. f/k/a Chartis Aerospace
Insurance Services, Inc. (“AIG”) files this Unopposed Motion for Extension of
Time to file its Appellee’s Brief, and would respectfully show the Court as
follows:
1. AIG’s Appellee’s Brief is currently due on December 4, 2015.
2. AIG seeks a 30-day extension in which to file its brief, such that its
brief would be due on or before January 4, 2016.1
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The 30th day actually falls on Sunday, January 3, 2016.
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3. AIG requests this extension because the undersigned, lead appellate
counsel, has had or will have several deadlines that have interfered with his ability
to fully review and analyze the record prior to receiving Appellants’ brief, and that
will interfere with his ability to adequately prepare Appellee’s Brief by the current
deadline, including:
(a) Preparing for and participating in oral argument on October 13, 2015
in the Louisiana Third Circuit Court of Appeals in docket number 15-00461-CA,
styled: Hayward Allen, III v. PHI, Inc., et al;
(b) Preparing Appellant’s Reply Brief in the United States District Court
For the District Of Delaware in case number: 15-346-LPS, Bankruptcy Case No.
09-12261, Bankruptcy Adversary Proceeding Number 11-52423, which was filed
on November 2, 2015; and
(c) Preparing a Petition for Writ of Mandamus in Texas’ Tenth Court of
Appeals in a case that will be styled In re Continental Motors, Inc., et. al., which is
due on or before November 24, 2015.
4. In addition to the above-referenced deadlines, the undersigned was out
of state from November 2-4, 2015 to assist an immediate family member
undergoing an emergency medical procedure, and will be traveling out of state
again for another procedure that will be set at some point in late November or early
December.
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5. This extension is not sought for delay, but so that the undersigned can
adequately prepare AIG’s brief.
6. The undersigned has conferred with lead appellate counsel for
Appellants, who has stated that Appellants are not opposed to this motion.
Respectfully submitted,
/s/ Steven D. Sanfelippo
Steven D. Sanfelippo
State Bar No. 24027827
CUNNINGHAM SWAIM, LLP
7557 Rambler Rd., Suite 440
Dallas, Texas 75231
(214) 646-1495
(214) 613-1163 - facsimile
ssanfelippo@cunninghamswaim.com
CERTIFICATE OF CONFERENCE
The undersigned hereby certifies that he has conferred with counsel for
Appellants, who has stated that Appellants do not oppose this motion for
extension.
/s/ Steven D. Sanfelippo
Steven D. Sanfelippo
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CERTIFICATE OF SERVICE
On November 11, 2015, I served a copy of this document to the following
counsel for Appellants Monty Clay, et al.
Michael A. Simpson
Simpson Boyd Powers & Williamson
P O Box 685
Bridgeport, TX 76426
D. Bryan Hughes
Law Office of D. Bryan Hughes
701 N Pacific Ave
Mineola, TX 75773
M. Keith Dollahite
M. Keith Dollahite, PC
5457 Donnybrook Ave
Tyler, TX 75703
Robert Waltman
Waltman & Grisham
2807 S Texas Ave, Ste 201
Bryan, TX 77802
William Angelley
Braden, Varner & Angelley, PC
703 McKinney Ave, Suite 400
Dallas, TX 75202
/s/ Steven D. Sanfelippo
Steven D. Sanfelippo
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