Jody Long v. Aeronautical Industrial District Lodge 776 Paul Black, in His Official Capacity as President-Directing Business Representative of District Lodge 776 And Earnest Boone, in His Official Capacity as Secretary-Treasurer of District Lodge 776

• Court: Court of Appeals of Texas
• Decided: May 24, 2018
• Docket: 02-18-00139-CV
• Status: Published

Opinion

ACCEPTED 02-18-00139-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 5/24/2018 3:06 PM DEBRA SPISAK CLERK

NO. 02-18-00139-CV

IN THE COURT OF APPEALS FILED IN 2nd COURT OF APPEALS FOR THE SECOND DISTRICT OF TEXASFORT WORTH, TEXAS AT FORT WORTH 5/24/2018 3:06:31 PM DEBRA SPISAK Clerk JODY LONG,

Appellant, v.

AERONAUTICAL INDUSTRIAL DISTRICT LODGE 776; PAUL BLACK, In His Official Capacity As President- Directing Business Representative of District Lodge 776; and EARNEST BOONE, In His Official Capacity As Secretary-Treasurer of District Lodge 776,

Appellees.

Appeal from the 342nd Judicial District Court, Tarrant County, Texas Trial Court Cause No. 342-295833-17 The Honorable Dana Womack, Presiding

AGREED MOTION TO EXTEND DEADLINE TO FILE APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS: Appellant Jody Long respectfully moves the Court to extend the time for filing

Appellant’s Brief by 30 days, to and including July 2, 2018. Appellees do not oppose

this requested extension.

1. The Appellant’s Brief is currently due on May 31, 2018.

Agreed Motion to Extend Deadline to File Appellant’s Brief Page 1 2. Appellant requests a 30 day extension of time to file Appellant’s Brief,

to and including June 2, 2018. See Tex. R. App. P. 4.1.(a).

3. Appellant is requesting this extension to allow the parties time to

finalize a settlement agreement. A settlement has been reached in principle, and the

parties are just working out the details of the settlement.

4. Appellant seeks this extension not solely for delay, but so that justice

may be done.

5. As reflected in the Certificate of Conference below, Appellees are in

agreement with the requested extension.

Respectfully submitted,

/s/ Lu Pham Lu Pham State Bar No. 15895430 lpham@dphllp.com Jennifer Bley Sweeny State Bar No. 24064910 jsweeny@dphllp.com DOWELL PHAM HARRISON, LLP 505 Pecan Street, Suite 200 Fort Worth, Texas 76102 817-632-6300 817-632-6311 – fax

And

Agreed Motion to Extend Deadline to File Appellant’s Brief Page 2 David E. Keltner State Bar No. 11249500 david.keltner@kellyhart.com Joe Greenhill State Bar No. 24084523 joe.greenhill@kellyhart.com KELLY HART & HALLMAN LLP 201 Main Street, Suite 2500 Fort Worth, Texas 76102 817-332-2500 817-878-9280 - fax

ATTORNEYS FOR APPELLANT

CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with counsel for Appellees, Rod Tanner, regarding the extension requested in this Motion. Mr. Tanner confirmed that Appellees agree to the relief requested in this Motion.

/s/ Lu Pham Lu Pham

CERTIFICATE OF SERVICE

I hereby certify that on May 24, 2018, a copy of this Motion was served via e-filing on all counsel of record as follows:

Rod Tanner rtanner@rodtannerlaw.com Charles Hairston chairston@rodtannerlaw.com TANNER AND ASSOCIATES, PC 6300 Ridglea Place, Suite 407 Fort Worth, TX 76116-5706 Attorneys for Appellees

Agreed Motion to Extend Deadline to File Appellant’s Brief Page 3