Dennis Webb v. State Farm Lloyds

FILED 17-0400 12/20/2017 1:23 PM tex-21407597 SUPREME COURT OF TEXAS BLAKE A. HAWTHORNE, CLERK No. 17-0400 The Supreme Court of Texas STATE FARM LLOYDS Petitioner / Cross-Respondent v. DENNIS WEBB Respondent / Cross-Petitioner On Petition for Review from the Ninth Court of Appeals—Beaumont, Texas No. 09-15-00408-CV JOINT MOTION FOR EXTENSION OF TIME TO FILE REPLIES TO THE PETITIONS FOR REVIEW Petitioner State Farm Lloyds and Cross-Petitioner Dennis Webb file this Joint Motion for Extension of Time to file replies to the responses to the Petitions for Review filed by the parties pursuant to Texas Rule of Appellate Procedure 10.5(b), and respectfully states as follows: 1. This is the first request for an extension of time to file replies to the petitions for review in this case. 2. The current deadline for State Farm Lloyds to file its motion is January 4, 2018. 3. The current deadline for Webb to file his motion is also January 4, 2018. 4. The parties have agreed to request an extension of the deadline to file their motions until and including Monday, February 5, 2018. The extension is needed to accommodate counsel for both parties, who have numerous preexisting family obligations associated with the Christmas and New Year’s holidays. The relief sought by this motion is so that justice may be done, and is not sought solely for delay or any other improper purpose. PRAYER WHEREFORE, Petitioner State Farm Lloyds and Cross-Petitioner Dennis Webb respectfully request the Court extend the response deadline until and including February 5, 2018. 2 Dated: December 20, 2017 Respectfully submitted, By: /s/ J. Hampton Skelton By: /s/ Gregory F. Cox (with permission) J. Hampton Skelton Gregory F. Cox State Bar No. 18457700 State Bar No. 00793561 hskelton@skeltonwoody.com Brandon Kinard Edward F. Kaye State Bar No. 24079744 State Bar No. 24012942 THE MOSTYN LAW FIRM ekaye@skeltonwoody.com 6280 Delaware Street Eva C. Ramos Beaumont, Texas 77706 State Bar No. 20143100 Tel: (409) 832-2777 eramos@skeltonwoody.com Fax: (409) 832-2703 SKELTON & WOODY 248 Addie Roy COUNSEL FOR Building B, Suite 302 DENNIS WEBB Austin, Texas 78746-4100 Tel: (512) 651-7000 Fax: (512) 651-7001 COUNSEL FOR STATE FARM LLOYDS 3 CERTIFICATE OF CONFERENCE I hereby certify that counsel for State Farm Lloyds conferred with counsel for Dennis Webb concerning the merits of this Joint Motion for Extension of Time to File Replies to the Petitions for Review. All parties are in agreement concerning the relief sought herein. /s/ J. Hampton Skelton J. Hampton Skelton CERTIFICATE OF SERVICE I hereby certify that on December 20, 2017, counsel of record listed below was served with a copy of the foregoing document via facsimile. I further certify that on the same date, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which may send notification of such filing to counsel of record: Mr. Gregory F. Cox Via facsimile (409) 832-2703 Mr. Brandon Kinard THE MOSTYN LAW FIRM 6280 Delaware Street Beaumont, Texas 77706 /s/ J. Hampton Skelton J. Hampton Skelton 4