ACCEPTED
03-15-00384-CV
6555230
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/19/2015 9:24:00 AM
JEFFREY D. KYLE
NO. 03-15-00384-CV CLERK
CRYSTAL BINGHAM HERNANDEZ § IN THE COURT OF APPEALS
Appellant FILED IN
§ 3rd COURT OF APPEALS
AUSTIN, TEXAS
VS. § FOR THE
8/19/2015 9:24:00 AM
§
JEFFREY D. KYLE
TIFFANY POLLEY § THIRD DISTRICT OF TEXAS
Clerk
Appellee
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes CRYSTAL BINGHAM HERNANDEZ, Appellant in the above styled and
numbered cause, and moves this Court to grant an extension of time to file appellant's brief,
pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the
following:
1. This case is on appeal from the County Court at Law No. 2 of Tom Green County,
Texas.
2. The case below was styled Crystal Bingham Hernandez v. Tiffany Polley, and
numbered 1 2C482-L2.
3. Notice of Appeal was filed with this Court on June 24,2015.
4. The Clerk's Record was filed with this Court on July 13, 2015. The Reporter's
Record was filed with this Court on July 22, 2015.
5. Appellant's brief is presently due on August 21, 2015.
6. Appellant requests a 30-day extension from the present deadline of August 21,
2015 to September 20, 2015.
7. No extension to file the brief has been requested or received in this cause.
8. Appellant's counsel relies on the following facts as good cause for the requested
extension:
The Reporter's Record filed in this case is a lengthy multi-volume Record. Counsel for
Appellant needs additional time to research and evaluate all potential issues that may be advanced
on appeal.
Counsel for Appellant has an extensive caseload of civil, criminal and family cases
pending in various county and district courts. Counsel for Appellant has been required to
participate in numerous contested cases following the filing of this appeal. Counsel for Appellant
is currently preparing for jury trial in a civil case in Val Verde County, Texas which is set for trial
on August 24, 2015.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this
Motion to Extend Time to File Appellant's Brief, and for such other and further relief as the Court
may deem appropriate.
Respectfully submitted,
The Law Offices of Rick Delloyos
502 South Irving Street
San Angelo, Texas 76903
rick@dehoyoslawfirm.com
Tel: (325) 658-8000
Fax: (325) 227-6913
State Bar No. 05644
ATTORNEY FOR APPELLANT
CERTIFICATE OF CONFERENCE
This is to certify that on August ( , 2015, I contacted Mr. Kirk D. Willis' office in an
effort to determine if he was unopposed or opposed to this Court granting an extension of thirty
days for the filing of Appellant's Brief. I certify that I have discussed this motion with Mr. Kirk
D. Willis, and he is NOT OPPOSED to this motion.
ik DeHoyos
Attorney for Appellan
CERTIFICATE OF SERVICE
I 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 of record on this ft day of August, 2015, as
follows:
Via Fax Transmission: (214) 736-9994
Kirk D. Willis
The Willis Law Group, PLLC
10440 N. Central Expy., Suite 520
Dallas, TX 75231