ACCEPTED
03-15-00293-CV
7145866
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/29/2015 1:39:22 PM
JEFFREY D. KYLE
CLERK
_________________________________________________
NO. 03-15-00293-CV FILED IN
_________________________________________________3rd COURT OF APPEALS
AUSTIN, TEXAS
9/29/2015 1:39:22 PM
In the Court of Appeals JEFFREY D. KYLE
For the Third Judicial District of Texas Clerk
Austin, Texas
____________________________________________________
BOB E. WOODY,
Plaintiff-Appellant,
v.
J. BLACK’S, LP and J. BLACK’S, GP, LLC,
Defendants-Appellees.
________________________________________________________________________
On Appeal from Cause No. D-1-GN-09-001436
In the 345th Judicial District Court of Travis County, Texas
The Honorable Steven Yelenosky Presiding
Appellees’ Unopposed Motion for
Extension of Time to File Brief in Response to Brief of Appellant
Bob E. Woody
TO THE HONORABLE COURT OF APPEALS:
Appellees’ opening brief currently is due October 19, 2015. Pursuant to Texas
Rule of Appellate Procedure 38.6(d), appellees respectfully request a 60-day extension of
time until December 18, 2015 to file their Brief in Response to Appellant Bob E. Woody.
This extension is requested for the following reasons.
1
In addition to other personal and professional obligations, the undersigned will have
personal and professional responsibility for the following additional commitments during
October 2015:
Two week trial set in the 201st Judicial District Court of Travis County,
Texas in Cause No. GN-13-00516, Nancy Schaefer vs. Michael J. Delitta, et
al.
Various pre-trial hearings for November 2, 2015 trial in In re: Life Partners
Holdings, Inc., Case No. 15-40289-RFN-11, In the United States Bankruptcy
Court For the Northern District of Texas, Fort Worth Division
Various hearings scheduled in In re: Victory Medical Center, et al., Case No.
15-42373-rfn-11, In the United States Bankruptcy Court for the Northern
District of Texas, Fort Worth Division
Although the undersigned has not given these commitments priority over the current
appeal, the undersigned could not complete the Appellees’ Brief in Response in this matter
by October 19, 2015 given the deadlines in these other matters.
The undersigned has confirmed that appellant is unopposed to this motion and
agreed to this extension.
No prior extensions have been previously requested or granted.
Prayer
Appellees respectfully request that the Court grant them a 60-day extension of time
to file their Brief in Response.
2
Respectfully submitted,
TAUBE SUMMERS HARRISON TAYLOR
MEINZER BROWN, LLP
By: /s/ Eric Taube
Eric Taube
State Bar No. 19679350
etaube@taubesummers.com
Andrew Vickers
State Bar No. 24084021
avickers@taubesummers.com
100 Congress Avenue, Suite 1800
Austin, Texas 78701
Telephone: (512) 472-5997
Telecopier: (512) 472-5248
ATTORNEYS FOR APPELLEES
CERTIFICATE OF CONFERENCE
On September 28, 2015, I conferred with appellant’s counsel regarding this
motion, and on September 29, 2015 they informed me that appellant was unopposed
to the relief requested herein.
/s/ Eric Taube
Eric Taube/Andrew Vickers
3
CERTIFICATE OF SERVICE
I certify that on September 29, 2015, a true and correct copy of the foregoing
document was served on the following counsel of record by electronic filing:
Tom C. McCall
tmccall@themccallfirm.com
David B. McCall Rick Gray
dmccall@themccallfirm.com Rick.gray@graybecker.com
THE MCCALL FIRM GRAY & BECKER, PC
3660 Stoneridge Road, Suite 900 West Avenue
F-102 Austin, Texas 78701
Austin, TX 78746-7759 Telecopier: (512) 482-0924
Telecopier: (512) 477-2271
Hector H. Cárdenas, Jr.
Jeremy J. Gaston hcardenas@cardenas-law.com
jgaston@hmgllp.com THE CÁRDENAS LAW FIRM
HAWASH, MEADE, GASTON, 3660 Stoneridge Road, Suite
NEESE & CICACK, LLP F-102
2118 Smith Street Austin, TX 78746
Houston, Texas 77002 Telecopier: (512) 477-2271
Telecopier: (713) 658-9011
/s/ Eric Taube
Eric Taube
4
Bob E. Woody v. J. Black's, LP And J. Black's GP, LLC
Combined Opinion