ACCEPTED
03-15-00384-CV
7976738
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/24/2015 3:29:44 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00384- V
C RY TAL BI NGHAM H ERNANDEZ § IN THE COU I~T OF APPEAL
Appellant FILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
vs. § FOR THE 11/24/2015 3:29:44 PM
§ JEFFREY D. KYLE
TIFFANY POLLEY § THIRD DISTRICT OF TEXA Clerk
Appellee
MOTION TO EXTEND TIME TO FILE APPELLANT' REPLY BRI EF
TO THE HONORABLE JU TICES OF AID COURT:
Now comes CRY TAL BING II AM II ERNANDEZ, Appellant in the above styled and
numbered cause. and moves this Court to grant an extension of time to tile Appellant's reply brief.
pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure. and for good cause shows the
folio" ing:
I. Thi case is on appeal from the County Court at Law No.2 of Tom Green County.
Texas.
2. The case below "'as st) led Cr) sta l Bingham I krnandez '. Tiffan) Polle) , and
numbered 12C482-L2.
3. Notice of Appeal was fi led with this Court on June 24, 2015.
4. The C lerk's Record wa tiled "'ith this Court on July 13. 2015. The Reporter's
Record was fil ed wi th this o ur1 o n Ju ly 22. 20 15.
5. Appellant's brief was tiled on eptember 18. 2015.
6. Appellee's responsive briefwas fil ed o n November 18.2015.
7. Appel lant' s rcpl) brief is due on December 8. 2015.
8. Appel lant req uests a 30-da) C. tension rrom the present dead line of December 8.
20 15 to January 7. 20 16.
9. No extension to fi le the Appellant" s repl) brief has been requested or received in
thi s cause.
I 0. Appellanf s counse l re lies on the following facts as good cause for the requested
extension:
Counsel lo r Appellant has an ex tensive cascload of civil. criminal and fami ly cases
pendi ng in various coun ty and district co urts. For this reason and because of the upcoming
Thanksgiving hotida), Counse l for Appellant req uests add iti onal ti me to research and fi le
Appell ant's response brief.
WH EREFORE, PREM ISES CONSIDERED. Appellant pra)s that thi s Court grant this
Motion to Extend Time to File ppellant's Rep!) Brief. and for such other and further relief as the
Court may deem appropriate.
Respectful ly submitted,
The Law Offices of Jlick DeHoyos
502 outh Irving Street
an Angelo. Texas 76903
rick a dcho' o~lav. li nn.wm
Tel: (325) 658-8000
Fax: (325) 227-69 13
~ ~o:fvo;- - t"" c;::: 4
tate Bar No. 05644085
ATTORNEY FO R APP ELLANT
CERT I FI CATE OF CONFERENCE
Thi s is to certi fy that on November 2C/-h-. 20 15, I contacted Ms. Lorin M. ubar,
Allorney for Appell ee. and di scussed this motion with her. and she is NOT OPPOS · D to th is
moti on.
CERTIFI CATE OF ERVI CE
1 hereby certify that a true and correct copy of the foregoing Motion to Extend Time to
File Appellant's Brief was served on all counsel or record on thi s ~ ay of November.
20 15. as follows:
Via Fru: Transmission: (214) 736-9994
Lorin M., ubar
The Willis Law Group, PLLC
I 0440 N. Central Expy .. Suite 520
Dallas. TX 75231
Crystal Bingham Hernandez v. Tiffany Polley
Combined Opinion