ACCEPTED
02-17-00413-CV
SECOND COURT OF APPEALS
FORT WORTH, TEXAS
12/21/2017 2:55 PM
DEBRA SPISAK
CLERK
No. 02-17-00413-CV
FILED IN
2nd COURT OF APPEALS
City of Fort Worth, Texas, * In the Court of Appeals
FORT WORTH, TEXAS
12/21/2017 2:55:54 PM
Appellant *
DEBRA SPISAK
vs. * Second District of Clerk
Texas
Mary Deal, *
Appellee * Fort Worth, Texas
APPELLEE'S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE'S BRIEF
Appellant City of Fort Worth, Texas, filed its brief in this accelerated
appeal on December 20, 2017. Under TRAP Rule 38.6, the brief of Appellee
Mary Deal is due to be filed by January 9, 2018. In accord with TRAP Rule
10.5(b)(1) and the Internal Operating Procedures of this Court, Appellee
requests the Court to grant a 20-day extension of the deadline for filing her
brief, until January 29, 2018. This extension is requested in part because
Appellee's counsel (the undersigned) has various other obligations and
plans during the upcoming holidays, ending January 2, 2018. Further, as a
solo practitioner handling a case in an area of the law previously unfamiliar
to him, Appellee's counsel needs additional time to assure a thorough yet
succinct response to Appellant's just-filed brief. Appellee has not received
any previous extensions of her briefing deadline, and Appellant does not
oppose Appellee's request.
Respectfully submitted,
/s/ Joe Riddell
Joe Riddell
Texas Bar No. 16886500
PO Box 41898
Austin, Texas 78704
email: joeriddell@aol.com
phone: 512-663-4669
fax: none
Attorney for Appellee, Mary Deal
CERTIFICATE OF CONFERENCE
By my signature below, I, Joe Riddell, counsel for Appellee, certify that on
December 20, 2017, I conferred with Laetitia Brown, counsel for Appellant,
regarding the 20-day extension requested in this Motion, and she does not
oppose it.
/s/ Joe Riddell
CERTIFICATE OF SERVICE
By my signature below, I, Joe Riddell, counsel for Appellee, certify that I
am serving the foregoing APPELLEE'S UNOPPOSED FIRST MOTION FOR
EXTENSION OF TIME TO FILE APPELLEE'S BRIEF by emailing it via the
efile.txcourts portal to Laetitia Brown, counsel for Appellant, at
laetitia.brown@fortworthtexas.gov on December 21, 2017.
/s/ Joe Riddell