Craig A. Washington v. Commission for Lawyer Discipline

Opinion

ACCEPTED 03-15-00083-CV 5595846 THIRD COURT OF APPEALS AUSTIN, TEXAS 6/9/2015 10:06:51 AM JEFFREY D. KYLE CLERK

No. 03-15-00083-CV FILED IN 3rd COURT OF APPEALS ___________________________________________________________ AUSTIN, TEXAS 6/9/2015 10:06:51 AM In the Third District Court of Appeals JEFFREY D. KYLE Houston, Texas Clerk ___________________________________________________________

CRAIG A. WASHINGTON,

Appellant,

vs.

COMMISSION FOR LAWYER DISCIPLINE,

Appellee. ___________________________________________________________

UNOPPOSED MOTION OF CRAIG A. WASHINGTON TO EXTEND DEADLINE FOR PRINCIPAL BRIEF

___________________________________________________________

Appellant Craig A. Washington asks that this Court extend for thirty (30)

days the deadline for the filing of his principal brief as the appellant in the

above-captioned case, making the new briefing deadline August 3, 2015. In

support Mr. Washington states:

1. This is an appeal from a final judgment signed January 8, 2015. The

completed clerk’s record was filed June 2, 2015, and the reporter’s record was

filed May 15, 2015. Therefore, the principal brief of the appellant is due July 2,

2015. TEX. R. APP. P. 38.6(a). This court can extend that deadline. Id. 38.6(d). This

is the appellants’ first request to extend the deadline, and it is unopposed.

1 2. Counsel for Mr. Washington, John MacVane, will be responsible for

the initial drafting of the brief and has a long-scheduled vacation the week of

July 2. In addition, Mr. MacVane has significant responsibility for the drafting of

a brief due June 23, 2015, a week before Mr. Washington’s deadline in this case.

That brief, due in Crimson Exploration, Inc., et al. v. Magnum Producing, LP, No.

12-15-13, in the Thirteenth Court of Appeals, involves a complex appeal of an oil-

and-gas title dispute with a 4,265 page clerk’s record.

3. In order to adequately focus on the briefing in this case and to

accommodate Mr. MacVane’s other briefing obligations and long-standing

vacation plans, Mr. Washington requests a 30-day extension of the deadline for

his appellant’s brief. A 30-day extension of the briefing deadline would make

appellants’ brief due on Monday, August 2, 2015.

2 Request for Relief

For the above reasons, Craig A. Washington asks this Court to extend for

30 days the deadline for the filing of his principal brief in this appeal, making the

new deadline August 3, 2015.

Respectfully submitted,

/s/ John MacVane Gardere Wynne Sewell LLP Michael A. Stafford 1000 Louisiana, Suite 3400 Texas Bar No. 18996970 Houston, Texas 77002-5007 Katharine David Tel: 713.276.5500 Texas Bar No. 24045749 Fax: 713.276.5555 John MacVane mstafford@gardere.com Texas Bar No. 24085444 kdavid@gardere.com jmacvane@gardere.com

ATTORNEYS FOR CRAIG A. WASHINGTON, APPELLANT

3 CERTIFICATE OF SERVICE

I certify that a copy of this document was served on June 9, 2015, by

delivery to the following counsel via the Electronic Filing Manager:

Cynthia Canfield Hamilton Office of the Chief Disciplinary Counsel State Bar of Texas Post Office Box 12487 Austin, Texas 78711 chamilton@texasbar.com

/s/ John MacVane John MacVane

Certificate of Conference

The parties’ counsel have conferred regarding the relief requested in this

motion. Counsel for the appellee—Commission for Lawyer Discipline—

indicated that it will not oppose this request for relief.

/s/ John MacVane John MacVane

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