Crystal Bingham Hernandez v. Tiffany Polley

Opinion

ACCEPTED 03-15-00384-CV 7976738 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/24/2015 3:29:44 PM JEFFREY D. KYLE CLERK NO. 03-15-00384- V

C RY TAL BI NGHAM H ERNANDEZ § IN THE COU I~T OF APPEAL Appellant FILED IN 3rd COURT OF APPEALS § AUSTIN, TEXAS vs. § FOR THE 11/24/2015 3:29:44 PM § JEFFREY D. KYLE TIFFANY POLLEY § THIRD DISTRICT OF TEXA Clerk Appellee

MOTION TO EXTEND TIME TO FILE APPELLANT' REPLY BRI EF

TO THE HONORABLE JU TICES OF AID COURT:

Now comes CRY TAL BING II AM II ERNANDEZ, Appellant in the above styled and

numbered cause. and moves this Court to grant an extension of time to tile Appellant's reply brief.

pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure. and for good cause shows the

folio" ing:

I. Thi case is on appeal from the County Court at Law No.2 of Tom Green County.

Texas.

2. The case below "'as st) led Cr) sta l Bingham I krnandez '. Tiffan) Polle) , and

numbered 12C482-L2.

3. Notice of Appeal was fi led with this Court on June 24, 2015.

4. The C lerk's Record wa tiled "'ith this Court on July 13. 2015. The Reporter's

Record was fil ed wi th this o ur1 o n Ju ly 22. 20 15.

5. Appellant's brief was tiled on eptember 18. 2015.

6. Appellee's responsive briefwas fil ed o n November 18.2015.

7. Appel lant' s rcpl) brief is due on December 8. 2015.

8. Appel lant req uests a 30-da) C. tension rrom the present dead line of December 8.

20 15 to January 7. 20 16. 9. No extension to fi le the Appellant" s repl) brief has been requested or received in

thi s cause.

I 0. Appellanf s counse l re lies on the following facts as good cause for the requested

extension:

Counsel lo r Appellant has an ex tensive cascload of civil. criminal and fami ly cases

pendi ng in various coun ty and district co urts. For this reason and because of the upcoming

Thanksgiving hotida), Counse l for Appellant req uests add iti onal ti me to research and fi le

Appell ant's response brief.

WH EREFORE, PREM ISES CONSIDERED. Appellant pra)s that thi s Court grant this

Motion to Extend Time to File ppellant's Rep!) Brief. and for such other and further relief as the

Court may deem appropriate.

Respectful ly submitted,

The Law Offices of Jlick DeHoyos 502 outh Irving Street an Angelo. Texas 76903 rick a dcho' o~lav. li nn.wm Tel: (325) 658-8000 Fax: (325) 227-69 13

~ ~o:fvo;- - t"" c;::: 4 tate Bar No. 05644085 ATTORNEY FO R APP ELLANT

CERT I FI CATE OF CONFERENCE

Thi s is to certi fy that on November 2C/-h-. 20 15, I contacted Ms. Lorin M. ubar, Allorney for Appell ee. and di scussed this motion with her. and she is NOT OPPOS · D to th is moti on. CERTIFI CATE OF ERVI CE

1 hereby certify that a true and correct copy of the foregoing Motion to Extend Time to File Appellant's Brief was served on all counsel or record on thi s ~ ay of November. 20 15. as follows:

Via Fru: Transmission: (214) 736-9994 Lorin M., ubar The Willis Law Group, PLLC I 0440 N. Central Expy .. Suite 520 Dallas. TX 75231