Lynda Bliss v. Bank of America N.A. and Santander Bank, N.A., F/K/A Sovereign Bank, N.A.

• Court: Court of Appeals of Texas
• Decided: June 5, 2018
• Docket: 05-18-00476-CV
• Status: Published

Opinion

ACCEPTED 05-18-00476-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 6/5/2018 2:04 PM LISA MATZ CLERK

NO. 05-18-00476-CV

LYNDA BLISS, § FIFTH DISTRICTFILED IN 5th COURT OF APPEALS Appellant, § DALLAS, TEXAS § 06/05/2018 2:04:41 PM vs. § COURT OF APPEALS LISA MATZ § Clerk Bank of America, N.A. AND § SANTANDER BANK, N.A., § Appellees. § AT DALLAS, TEXAS

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF

Appellant Lynda Bliss ("Bliss" or Appellant") submits this unopposed motion

requesting the Court to extend the time to file Appellant's Brief.

Appellant's Brief is currently due on June 6, 2018. There have been no previous

extensions of this briefing deadline.

Appellant's counsel, Jeffrey R. Sandberg of the lawfirm Palmer & Manuel, LLP, is

unable to file Appellant's Brief on or before this deadline.

On May 21, 2018, Mr. Sandberg filed the Appellant's Reply Brief in this Court in

WWLC Investment, L.P. v. Miraki in appellate cause 05-17-01126-CV. On May 21, 2018,

Mr. Sandberg filed Petitioners' Reply to the Response to the Petition for Review in the Texas

Supreme Court in appellate cause 18-0144. Additionally, Mr. Sandberg was the sole counsel

for a five-day jury trial in May 2018.

Because of this, Mr. Sandberg is unable to file Appellant's Brief on or before June 6,

2018, and Appellant requests additional time to file Appellant's Brief. At this time,

Appellant requests an additional thirty days to file Appellant's Brief, or a new deadline of

July 6, 2018. APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3 1:\18042\Appeal\Motion (Unopposed) to Extend Time to File Appellant Brief.180605 .. doc This motion is filed before the date Appellant's Brief is due on June 6, 2018. See

TEX. R. APP. P. 10.5.

PRAYER

For the above reasons, Appellant asks the Court to grant an extension of time to file

Appellant's Brief in this cause an additional thirty days, extending the time for Appellant to

file Appellant's Brief to July 6, 2018.

Respectfully submitted,

PALMER & MANUEL, PLLC

By: /s/ Jeffrey R. Sandberg Jeffrey R. Sandberg State Bar No. 00790051 jsandberg@pamlaw.com 8350 N. Central Expressway; Suite 1111 Dallas, Texas 75206 (214) 242-6444/ (214) 265-1950- Fax COUNSEL FOR APPELLANT LYNDA BLISS

CERTIFICATE OF CONFERENCE

Counsel certifies that on June 4, 2018, counsel conferred with Appellees' counsel regarding this motion and Appellees do not oppose the relief requested by Appellant.

/s/ Jeffrey R. Sandberg JEFFREY R. SANDBERG

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 2 of 3 1:\18042\Appeal\Motion (Unopposed) to Extend Time to File Appellant Brief.180605 .. doc VERIFICATION

STATE OF TEXAS § § COUNTY OF DALLAS §

BEFORE ME, the undersigned Notary Public, on this day personally appeared Jeff Sandberg, who, after being duly sworn, stated under oath stated that he has read the above document; that he is authorized to execute this Verification, and that every factual statement contained therein is within his personal le e and is true and correct.

SUBSCRIBED AND SWORN T BEFORE ME on the 5th day of June, 2018, to certify which witness my and official seal.

MARIA ISLAS A lifu ~ r21lt.S Notary ID #6532246 My Commission Expires Notary Public in and for the State of Texas September 7, 2021

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing has been forwarded to the following counsel of record in accordance with the Texas Rules of Appellate Procedure via electronic filing and email on this the 5th day of June, 2018:

Kathryn B. Davis, Esq.(kbdavis@winston.com) Connie Flores Jones, Esq.(cflores@winston.com) Winston & Strawn LLP 1111 Louisiana 25th Floor Houston, TX 77002

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3 1:\18042\Appeal\Motion (Unopposed) to Extend Time to File Appellant Brief.180605 .. doc