Brooke Bruce// Carter Bruce v. Carter Bruce// Cross-Appellee, Brooke Bruce

• Court: Court of Appeals of Texas
• Decided: November 17, 2016
• Docket: 03-16-00581-CV
• Status: Published

Opinion

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

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 4 OF 4