Thomas D. Young A/K/A T. David Young v. JP Morgan Chase Bank, N.A.

ACCEPTED
03-15-00261-CV
5840247
THIRD COURT OF APPEALS
AUSTIN, TEXAS
6/26/2015 12:06:07 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00261-CV

FILED IN
In the Third Court of Appeals 3rd COURT OF APPEALS
AUSTIN, TEXAS
6/26/2015 12:06:07 PM
Austin, Texas
JEFFREY D. KYLE
Clerk

THOMAS D. YOUNG A/K/A T. DAVID YOUNG, APPELLANT

v.

JP MORGAN CHASE BANK, N.A., APPELLEE

APPEAL FROM CAUSE NO. D-1-GN-12-000590
126TH DISTRICT COURT OF TRAVIS COUNTY, TEXAS
HON. DARLENE BYRNE PRESIDING

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE BRIEF

Stephen Casey
Texas Bar No. 24065015
ORAL
CASEY LAW OFFICE, P.C. ARGUMENT
595 Round Rock West Drive REQUESTED
Suite 102
Round Rock, Texas 78681
Telephone: 512-257-1324
Fax: 512-853-4098
stephen@caseylawoffice.us

Counsel for Appellant
Thomas D. Young a/k/a T. David Young

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 GROUNDS FOR MOTION

1. Appellant’s Brief is due to be filed in Court on July 1, 2015.

2. Appellant’s counsel has four (4) briefs coming due within a 2-week time frame.
Counsel is in need of more time to adequately draft and file Appellant’s Brief.

3. Appellant is asking for a 30-day extension.

4. This is Appellant’s first request for an extension.

PRAYER

For the foregoing reasons, Appellant prays the Court will grant the motion.

Respectfully submitted,

/s/ Stephen Casey

Stephen Casey
Texas Bar No. 24065015

595 Round Rock West Drive, Suite 102
Round Rock, Texas 78681
Telephone: 512-257-1324
Fax: 512-853-4098
stephen@caseylawoffice.us

CERTIFICATE OF CONFERENCE
I hereby certify that I have conferenced with opposing counsel, Marcie L.
Schout, via e-mail on June 25, 2015. Opposing counsel is unopposed to the
Motion for Extension of Time to File Appellant’s Brief.

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 /s/Stephen Casey

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing motion has
been served on Friday, June 26, 2015, on the following via electronic transmission:

Marcie L. Schout
Quilling, Selander, Lownds,
Winslett, & Moser, P.C.
2001 Bryan Street, Suite 1800
Dallas, TX 75201
mschout@qslwm.com

/s/ Stephen Casey

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