Johnny Partain v. State of Texas

Opinion

ACCEPTED 15-25-00005-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS No. 15-25-00005-CV 3/11/2025 1:01 PM CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS

In The AUSTIN, TEXAS 3/11/2025 1:01:06 PM

Fifteenth Court Of Appeals CHRISTOPHER A. PRINE Clerk

JOHNNY PARTAIN Appellant

v.

STATE OF TEXAS Appellee

Appellant’s Unopposed Motion For Extension Of Time to Submit Appellant’s Brief

JOHNNY R. PARTAIN 7020 N 16th Street McAllen, Texas 78504 956-240-1821 No. 15-25-00005-CV

In The Fifteenth Court Of Appeals

Appellant’s Unopposed Motion For Extension Of Time to Submit Appellant’s Brief

TO THE HONORABLE JUSTICES OF THIS COURT:

COMES NOW JOHNNY PARTAIN, Appellant in the above styled and

numbered cause and files his Appellant’s Unopposed Motion For Extension Of

Time To Submit Appellant’s Brief, and respectfully shows unto the Court the

following.

The existing deadline to file the Appellant’s Brief is March 10, 2025.

Appellant seeks a 15 day extension since his brief is not complete and the

Appellant’s time has been extraordinarily consumed for the past 30 days through

additional legal and business duties including a Motion For “New” Trial, multiple discovery requests, negotiating a new contract, pursuing multiple public

information requests, making a claim on a payment bond for a government project,

pursuing requests for certificates of service through the Texas Secretary of State,

and their attorney, for services that have already been completed within this

period, and a business audit. There have been no previous extensions.

Accordingly, Appellant motions this Court to extend the deadline 15 more

days to March 25, 2025, to file the Appellant’s Brief. Appellant motions for all

equitable and legal relief he may be entitled.

Respectfully Submitted,

___________________________ Johnny Partain 7020 N 16th Street McAllen, Texas 78504 partain@atlastechnologies.biz 956-240-1821 CERTIFICATE OF CONFERENCE As required by TRAP 10.1(a)(5), I certify that I have conferred, or made a reasonable attempt to confer, with all other parties through Ms. Ali Thorburn, Assistant Attorney General Litigation Division, Ali.Thorburn@oag.texas.gov, about the merits of this motion. Ms. Thorburn responded unopposed.

Date: March 11, 2025

CERTIFICATE OF SERVICE This certifies that a true and correct copy of the foregoing document has been serviced by email to Ms. Ali Thorburn, Assistant Attorney General General Litigation Division, Ali.Thorburn@oag.texas.gov on this March 11, 2025.

___________________________ Johnny Partain 7020 N 16th Street McAllen, Texas 78504 partain@atlastechnologies.biz 956-240-1821 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Envelope ID: 98317925 Filing Code Description: Motion Filing Description: Appellants Motion To Extend Time To File Status as of 3/11/2025 2:05 PM CST

Associated Case Party: State of Texas

Name BarNumber Email TimestampSubmitted Status

Ali Thorburn Ali.Thorburn@oag.texas.gov 3/11/2025 1:01:06 PM SENT