ACCEPTED
03-15-00533-CV
7767032
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/10/2015 2:18:29 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00533-CV
FILED IN
In the Court of Appeals 3rd COURT OF APPEALS
For the Third Court of Appeals District AUSTIN, TEXAS
Austin, Texas 11/10/2015 2:18:29 PM
JEFFREY D. KYLE
Clerk
LEAHSHIKE
Appellant,
v.
ANTHONYCHARLESFLOT
Appellee
On Appeal from the 335 1h Judicial District Court, Bastrop County, Texas
Trial Court Cause No. 29,439
APPELLANT'S UNOPPOSED FIRST MOTION TO
EXTEND TIME TO FILE APPELLANT'S BRIEF
HENSLEY LAW FIRM
Edward Hensley
SBN. 09492500
ed@hensleylawfirm.com
Deborah Hensley Loewe
SBN. 00793939
deborah@hensleylawfirm.com
3809 South 2"ct Street, Ste. A-100
Austin, Texas 78704
(512) 476-9988
(512) 327-9992, facsimile
Counsel for Appellant, Leah Shike
1
Identity of Parties and Counsel
Appellant/Plaintiff Plaintiff/Appellant's Appellate Counsel:
HENSLEY LAW FIRM
Edward Hensley
SBN. 09492500
ed@hensleylawfirm.com
Deborah Hensley Loewe
SBN. 00793939
deborah@hensleylawfirm.com
3809 South 2nd Street, Ste. A-100
Austin, Texas 78704
(512) 476-9988
(512) 327-9992, facsimile
Appellee/Defendant Defendant/Appellee's Appellate Counsel:
CLARK, TREVINO & ASSOCIATES
Ethan Goodwin
SBN. 24064492
ethan.goodwin@farmersinsurance.com
1701 Directors Boulevard, Ste. 920
Austin, Texas 78744
(512) 445-1580
(512) 383-0503, facsimile
1
TO THE HONORABLE THIRD COURT OF APPEALS:
Pursuant to Tex. R. App. P. 10.1 and 38.6(d), the Appellant, Leah Shike ("Appellant")
files this Unopposed First Motion to Extend Time to File Appellant's Brief.
Appellant's opening brief is currently due November 16,2015.
Counsel for Appellant requests a 30-day extension of time to file Appellant's brief,
making the brief due on December 16,2015. This is the first request for extension of time to file
the opening brief.
Counsel for Appellant relies on the following reasons, in addition to the routine matters
that counsel must attend to in daily practice, to explain the need for the requested extension:
• The undersigned has been under a heavy workload and it has been impossible to
reach this case for study and analysis and preparation of the Brieffor Appellant.
Counsel for Appellant seeks this extension of time to be able to prepare a persuasive and
concise briefto aid this Court in its analysis of the issues presented.
This request is not sought for delay but so that justice may be done.
The undersigned has conferred with Ethan Goodwin, counsel for the Defendant/Appellee,
and he has indicated that his client does not oppose this Motion.
All facts recited in this Motion are within the personal knowledge of the counsel signing
this Motion, therefore, no verification is necessary under Texas Rule of Appellate Procedure
10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this Unopposed
First Motion to Extend Time to File Appellant's Brief and extend the deadline for filing the
Appellant's Brief up to and including December 16, 2015. Appellant requests all other relief to
which she may be justly entitled.
1
Respectfully submitted,
ed@hensleylawfirm.com
Deborah Hensley Loewe
SBN. 00793939
deborah@hensleylawfirm.com
3809 South 2"d Street, Ste. A-100
Austin, Texas 78704
(512) 476-9988
(512) 327-9992, facsimile
ATTORNEYS FOR APPELLANT
CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. P. 10.1(5), I certify that the undersigned conferred with
opposing counsel who indicated that his client does not o
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Motion for Extension was
forwarded to the following counsel of record on this JJ2 day of {lw~ , 2015:
Via Facsimile (512/ 383-0503
Ethan Goodwin
Clark, Trevino & Associates
1701 Directors Boulevard, Ste. 920
Austin, Texas 78744
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Leah Shike v. Anthony Charles Flot
Combined Opinion