Denton Central Appraisal District v. Richard Scott Gladden

ACCEPTED 02-17-00400-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 12/21/2017 9:01 AM DEBRA SPISAK CLERK Cause No. 02-17-00400-CV FILED IN IN THE COURT OF APPEALS FOR THE 2nd COURT OF APPEALS FORT WORTH, TEXAS SECOND JUDICAL DISTRICT OF TEXAS12/21/2017 9:01:44 AM at Fort Worth, Texas DEBRA SPISAK _________________________________________________Clerk Denton Central Appraisal District, Appellant, v. Richard Scott Gladden, Appellee. _________________________________________________ Appealed from the 393rd Judicial District Court of Denton County, Texas Trial Court Cause No. 2013-94487-393 The Honorable Douglas M. Robison, Presiding Judge ___________________________________________________________ FIRST UNOPPOSED MOTION TO EXTEND TIME FOR FILING APPELLANT, DENTON CENTRAL APPRAISAL DISTRICT’S, BRIEF TO THE HONORABLE COURT OF APPEALS: Pursuant to Rules 10.5(b) and 38.6(d) of the Texas Rules of Appellate Procedure, the Appellant, Denton Central Appraisal District, moves this Court for a thirty (30) day extension of time to file its Appellee’s Brief, and respectfully states as follows: Page 1 of 5 I. INTRODUCTION AND SUPPORT FOR MOTION 1. Appellant is Denton Central Appraisal District; Appellee is Richard Scott Gladden. 2. The Appellant’s brief is currently due on, or before, January 15, 2018. 4. The Appellant needs additional time to file its brief because of its counsel’s prior work obligations, motion practice, administrative matters, vacation schedule and various settings throughout Texas. More specifically, counsel for the Denton Central Appraisal District has a brief currently due in the San Antonio Court of Appeals on January 11, 2018, and is scheduled to take vacation during the upcoming holidays. 5. Therefore, the Appellant, Denton Central Appraisal District, seeks a thirty (30) day extension of time to file its Appellant’s Brief, which, if granted, would make the Briefing due on or before Wednesday, February 14, 2018. 7. This is the Appellant’s first request and motion for an extension of time in this matter. 8. The requested extension of time is necessary to allow Appellant’s counsel sufficient time to prepare the brief and satisfy other pre-existing obligations. 9. Pro-se Appellee does not oppose this motion. Page 2 of 5 10. This extension is not being sought for purposes of delay, but so the issues involved in this case may be properly briefed and presented to this Court. II. CONCLUSION & PRAYER 11. For these reasons, the Appellant, Denton Central Appraisal District, respectfully requests that this Court grant this, its First Unopposed Motion to Extend Time for Filing its Appellant’s Brief and extend the deadline for timely filing said Brief from Monday, January 15, 2018 to Wednesday, February 14, 2018. Respectfully submitted, /s/ A. Dylan Wood A. Dylan Wood Texas Bar Number: 00797689 PERDUE, BRANDON, FIELDER, COLLINS & MOTT, L.L.P. 3301 Northland Dr., Suite 505 Austin, Texas 78731 Telephone: (512) 302-0190 Facsimile: (512) 323-6963 email: dwood@pbfcm.com ATTORNEY FOR APPELLANT, DENTON CENTRAL APPRAISAL DISTRICT Page 3 of 5 CERTIFICATE OF CONFERENCE Pursuant to Tex. R. App. P. 10.1(a)(5), the undersigned confirms that Mr. Richard Scott Gladden, Appellee pro-se, was conferred with regarding the merits of Appellant’s First Unopposed Motion to Extend Time for Filing Appellant, Denton Central Appraisal District’s, Brief, and he is unopposed. /s/ A. Dylan Wood A. Dylan Wood Page 4 of 5 CERTIFICATE OF SERVICE This is to certify that pursuant to Tex. R. App. P. 6.3, 9.5, Tex. R. Civ. P. 21 and 21a, on the 21st day of December 2017, a true and correct copy of the foregoing First Unopposed Motion to Extend Time for Filing Appellant, Denton Central Appraisal District’s, Brief was served upon Appellee, via e-service on the same date. Mr. Richard Scott Gladden 1200 W. University Dr., Ste. 100 Denton, Texas 76201 email: richscot1@hotmail.com Appellee, pro-se /s/ A. Dylan Wood A. Dylan Wood Page 5 of 5