Mondee Stracener v. Doug Stracener, Bernice L. Stracener and Joey Keith Stracener

Opinion

ACCEPTED

06-14-00079-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

3/11/2015 8:34:25 AM

DEBBIE AUTREY

CLERK

Cause No.: 06-14-00079-CV

IN THE COURT OF APPEALS

SIXTH DISTRICT OF TEXAS AT TEXARAKANA FILED IN 6th COURT OF APPEALS

TEXARKANA, TEXAS

MONDEE STRACENER, Appellant 3/11/2015 4:28:00 PM

DEBBIE AUTREY

v. Clerk

DOUG STRACENER, BERNICE L. STRACENER AND JOEY KEITH STRACENER, Appellees

APPELLEES' MOTION FOR ADDITIONAL TIME TO FILE APPELLEES' BRIEF TO THE HONORABLE JUDGE OF SAID COURT:

Come now, Doug Stracener, Bernice L. Stracener, and Joey Keith Stracener, hereinafter referred to as Appellees, and file this Motion for Additional Time to File Appellees' Brief.

I.

The deadline for filing Appellees' Brief is March 13, 2015.

II.

Appellees have been unable to file Appellees' Brief for the filing reasons , for which constitute good cause for the extension of time:

1. The undersigned attorney has been required to submit a brief to the 2761h Judicial District Court of Camp County, Texas, in Cause No . No. CV-13-2156, which was due February 13, 2015.

2. The undersigned attorney has prepared for a trial in the County Court at Law No. 2 of Dallas County, Texas , in Cause No. CC-13-00417-B, which was scheduled for the

Appellees' Motion fo r Additional Time to File Appellees' Brief Page 1 week of February 16, 2015, but canceled after time had already been spent preparing for the trial;

3. The undersigned attorney had a trial in the 2761h Judicial District Court of Camp County, Texas, in Cause No. No. CV-14-2384, on February 27 , 2015;

4. The undersigned is further has scheduled depositions in Cause No. 2014-

1762-5, a case pending in District Court of Mclennan County, that require him to travel to Waco on March 10, 2015;

5. The undersigned is further scheduled for hearing on a Motion for Summary Judgment as well as various pretrial motions in the 76th/276th Judicial District of Camp County, Texas, in Cause No. No. CV-12-2016; and 6. The undersigned would further show that he has conferred with Mr. Robert M. Minton, attorney for Appellant, and Mr. Minton is not opposed to this Motion .

The undersigned , that in order to serve the interests of justice for all of is potentially effected clients, respectfully requests the Court to extend the time for filing Appellees' Brief to the 121h day of April, 2015. This request is not made for the purpose of delay, but so that the undersigned may adequately serve the interests of the legal profession in seeing to it that his clients are adequately advised, represented, and their work completed on time, as well as to handle the appeal of this proceeding .

Ill.

This extension of time is sought so that justice may be done and not for the pu rposes of delay.

Appellees' Motion for Additional Time to File Appellees' Brief Page 2

IV.

Granting this request for an extension of time to file will not delay the business of the Court.

WHEREFORE PREMISES CONSIDERED, Appellees request the Court to grant an extension of time until April 12, 2015, to file Appe llees' Brief.

Respectfully submitted:

GRIFFITH & GRIFFITH LAW FIRM , P.C.

404 North Titus

P.O. Box 864

Gilmer, Texas 75644-0864

Tel: (903) 843-5005

Fax: (903) 843-5392

E-Mail: davidg@griffithlawfirm .com Attorney for Appellees

Doug Stracener, Bernice L. Stracener and Joey Keith Stracener

CERTIFICATE OF SERVICE

~

I certify that on March / '!/ , 2015, a true and correct copy of Appellees'

Motion for Additional Time to File Appellees' Brief was served on Robert M. Minton via email to mintonbrown@suddenlinkmail.c~ ~

_..,David B .~Griffith

Appellees' Motion for Additional T ime to File Appellees' Brief Page 3