Mark J. Healey v. Edwin N. Healey

Opinion

ACCEPTED

12-15-00047-CV

TWELFTH COURT OF APPEALS

TYLER, TEXAS

11/2/2015 1:40:43 PM

Pam Estes

CLERK

Cause No. 12-15-00047-CV IN THE COURT OF APPEALS

FILED IN

FOR THE TWELFTH JUDICIAL DISTRICT 12th COURT OF APPEALS TYLER, TEXAS TYLER, TEXAS 11/2/2015 1:40:43 PM

PAM ESTES

Clerk

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MARK J. HEALEY APPELLANT

V.

EDWIN N. HEALEY

APPELLEE

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On Appeal from Cause No. 2014C-0638 From the 3rd District Court, Henderson County, Texas Honorable Mark Calhoon, Judge Presiding

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MOTION TO EXTEND TIME FOR FILING APPELLANT'S BRIEF

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TO THE HONORABLE JUDGE OF SAID COURT:

I.

Now comes Appellant is Mark J. Healey and moves the Court for an extension of time to November 30, 2015 to file his Reply Brief and in support thereof, would show the Court:

II.

The Appellant’s brief without extension is due November 10, 2015.

III.

A Reply Brief is needed in this cause to clearly present the issues to the Court.

IV.

Appellant’s attorney’s work schedule makes it extremely difficult to properly prepare a Reply Brief within the 20 day period of the filing of Appellee’s Brief and settlement discussions are in progress.

V.

No previous extensions of time have been requested or granted for Appellant’s Reply Brief.

VI.

Appellant’s attorney has conferred with Appellee’s attorney regarding this motion and Appellee’s attorney does not oppose this motion.

WHEREFORE, Appellant moves the Court for an extension of time until November 30, 2015 in which to file Appellant’s Reply Brief.

Respectfully submitted,

STARK & GROOM, LLP 110 E. Corsicana St. Athens, TX 75751 903-675-5691 Telephone 903-675-6454 Facsimile stevestark@starkandgroom.com Email

/s/ Steve Stark Steve Stark State Bar No. 19066000 Attorney for Appellant

CERTIFICATE OF CONFERENCE

Appellant’s Attorney hereby certifies that he conferred with Koy Killen by

telephone on October 29, 2015 and counsel does not oppose the requested extension.

_/s/_Steve Stark

CERTIFICATE OF SERVICE

I certify that on November 2, 2015 a true and correct copy of Appellant’s Motion To Extend Time of Filing Reply to Appellee’s Brief was served on all parties or counsel of record in accordance with rules.

Koy R. Killen Via Fax: 817-447-0052 104 South Main Street Burleson, Texas 76028

Paul C. Healey 3309 Heather Hill Garland, Texas 75044

_/s/_Steve Stark