Anna Marie Inman v. Equable Ascent Financial, LLC

• Court: Court of Appeals of Texas
• Decided: November 2, 2015
• Docket: 12-15-00220-CV
• Status: Published

Opinion

ACCEPTED 12-15-00220-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 11/2/2015 4:31:18 PM Pam Estes CLERK

No. 12-15-00220-CV

In the FILED IN 12th COURT OF APPEALS TYLER, TEXAS Twelfth Court of Appeals 11/2/2015 4:31:18 PM PAM ESTES Tyler, Texas Clerk ________________________________

ANNA MARIE INMAN, Appellant

VS.

EQUABLE ASCENT FINANCIAL, LLC, Appellee ________________________________

APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF

COMES NOW Anna Marie Inman, Appellant herein, and moves this

Court for an extension of time to file their brief under TRAP 38.6(d), and in

support thereof would show the following:

1. Appellant’s brief is now due on November 2, 2015.

2. Appellant requests a 30-day extension of the deadline for filing her

brief, or until December 2, 2015.

3. Appellant seeks this extension of time for several reasons. First, one

of the attorneys working on the brief, Heather Keegan, has not been able to

work on her assigned issue, because she has been busy dealing with

several hearings and outreach events over the past 3 weeks. Second,

while much of the brief assigned to the undersigned has been completed, more time is needed to finish some legal research and drafting on the one

issue being handled by the undersigned.

4. No previous extension of time to file a brief has been accorded by this

Court to Appellant. Counsel for Appellee Equable Ascent Financial, LLC

has informed counsel for Appellant that this motion is not opposed.

WHEREFORE, Appellants prays that this Honorable Court grant this

motion and extend the time for filing Appellant’s brief until January 30,

2015, and for such other and further relief to which they may be entitled.

Respectfully submitted,

LONE STAR LEGAL AID

By: /s/ Richard Tomlinson RICHARD TOMLINSON 1415 Fannin Houston, Texas 77002 713/652-0077, ext. 1154 Fax: 713/652-3814 State Bar No. 20123500

ATTORNEY FOR APPELLANT

Appellant’s Unopposed Motion for Extension of Time to File Brief Page 2 CERTIFICATE OF CONFERENCE

On November 2, 2015 pursuant to TRAP 10.1(a)(5), counsel for

Appellant sought to confer with counsel for Appellee, Dan G. Young of

Jenkins, Wagnon & Young, P.C., about the merits of this motion and

whether Appellee would oppose this motion. After leaving a message for

Mr. Young and e-mailing him, he responded by e-mail that he would not

oppose a 30-day extension of time for Appellant to file her brief.

/s/ Richard Tomlinson Richard Tomlinson

CERTIFICATE OF SERVICE

Pursuant to T.R.A.P. 9.5, I hereby certify that I served a copy of the

foregoing Appellant’s Unopposed Motion for Extension of Time by e-mail,

fax, certified mail, return receipt requested, or by hand delivery, on this the

2nd day of November, 2015, as follows:

Dan G. Young Jenkins, Wagnon & Young, P.C. P.O. Box 420 Lubbock, Texas 79408-0420 dgyservice@jwylaw.com ATTORNEY FOR APPELLEE

Appellant’s Unopposed Motion for Extension of Time to File Brief Page 3