ACCEPTED
03-16-00581-CV
13853976
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/17/2016 2:22:14 PM
JEFFREY D. KYLE
CLERK
NO. 03-16-00581-CV FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
11/17/2016 2:22:14 PM
JEFFREY D. KYLE
IN THE THIRD COURT OF APPEALS Clerk
AUSTIN, TEXAS
BROOKE BRUCE,
Appellant,
v.
CARTER BRUCE,
Appellee.
On Appeal from the 345th Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-FM-06-002028
FIRST MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
Kacy L. Dudley
State Bar No. 24069638
DUDLEY LAW, PLLC
1717 West Sixth Street, Suite 315
Austin, Texas 78703
(512) 617-3975 (telephone)
(512) 479-7910 (facsimile)
kdudley@dudley-law.com
COUNSEL FOR APPELLANT
TO THE HONORABLE THIRD COURT OF APPEALS IN AUSTIN, TEXAS:
Appellant Brooke Bruce (“Appellant”) files this First Motion for Extension of
Time to File Petition for Review under TEX. R. APP. P. 10.1, 10.5(b), and 38.6(d),
and in support thereof would respectfully show the following:
1. Appellant’s Brief is currently due on Monday, November 21, 2016.
Appellant requests an extension of time of thirty days, to December 21, 2016. This
is Appellant’s first request for an extension of time in this case.
2. The extension will permit counsel to fully analyze the record and
relevant law and thus prepare thorough briefing to aid the Court in its consideration
of this appeal: to conduct additional legal research as appropriate, and to include
such additional factual and legal support in the briefing to present to this Court.
3. In addition to preparing the briefs in this case, counsel for Appellant,
who is the sole attorney in her law practice, has recently devoted time to discovery
responses in two different matters due November 11 and November 15, various
hearings, mediations and attending a seminar in addition to the other legal and
administrative responsibilities of managing a law practice.
4. The undersigned has attempted to confer with opposing counsel, who
has not yet responded. This extension is not sought for delay, and no party will be
prejudiced if it is granted.
APPELLANT’S FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF PAGE 2 OF 4
For the foregoing reasons, Appellant respectfully requests that the Court grant
this thirty-day extension to file her brief, creating a new deadline of December 21,
2016.
Respectfully submitted,
DUDLEY LAW, PLLC
1717 West Sixth Street, Suite 315
Austin, Texas 78703
(512) 617-3975 Telephone
(512) 479-7910 Facsimile
By: /s/ Kacy L. Dudley
Kacy L. Dudley
State Bar No. 24069638
kdudley@dudley-law.com
CERTIFICATE OF CONFERENCE
As required by TEX. R. APP. P. 10.1(a)(5), I certify that via email on November
17, 2016, I attempted to confer with Ms. Cecilia Wood, counsel for CARTER
BRUCE, who has not yet indicated whether this motion is opposed.
/s/ Kacy L. Dudley
Kacy L. Dudley
CERTIFICATE OF SERVICE
APPELLANT’S FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF PAGE 3 OF 4
I hereby certify that a true and correct copy of the foregoing document was
served in accordance with the Texas Rules of Appellate Procedure on Thursday,
November 17, 2016 as follows:
Cecilia M. Wood
919 Congress Ave., Ste. 830
Austin, Texas 78701
Via Email: Cecilia@ceciliawood.com
Attorney for Carter Bruce
/s/ Kacy L. Dudley
Kacy L. Dudley
APPELLANT’S FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF PAGE 4 OF 4
Brooke Bruce// Carter Bruce v. Carter Bruce// Cross-Appellee, Brooke Bruce
Combined Opinion