Nash Jesus Gonzales and Gonzales & Gonzales, P.C. v. Marissa Ann Maggio

Opinion

ACCEPTED 03-14-00117-CV 3936097 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/28/2015 3:28:10 PM JEFFREY D. KYLE CLERK

NO. 03-14-00117-CV

NASH JESUS GONZALES and FILED IN IN THE COURT OF APPEALS § 3rd COURT OF APPEALS GONZALES & GONZALES, P.C., § AUSTIN, TEXAS Appellants § 1/28/2015 3:28:10 PM V. § THIRD JEFFREY D. KYLE JUDICIAL DISTRICT Clerk § MARISSA ANN GONZALES § Appellee § AUSTIN, TEXAS

AGREED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE COURT:

COMES NOW Appellee Marissa Ann Gonzales, and files her Agreed

Motion for Extension of Time to File Appellee’s Brief and respectfully shows the

Court as follows:

I.

MOTION FOR EXTENSION OF TIME

This case is on appeal from the 200th Judicial District Court in Travis

County, Texas. The appeal stems from the jury trial of a divorce and child

custody/support suit.

Appellant filed his Brief with the Court on January 16, 2015. According to

the Texas Rules of Appellate Procedure, Appellee’s brief is due on February 16,

2015.

The Court has authority to grant an extension of time. Tex. R. App. P.

10.5(b). Appellee seeks an extension of time of 60 days to file her Brief, making Page 1

April 17, 2015 the new deadline to file Appellee’s Brief. Appellee just recently

received an order of substitution of counsel on January 26, 2015. Appellee’s

counsel requests this extension of time due to their current case load including

prior travel commitments. No previous extension of time to file Appellee’s Brief

has been requested or granted.

IL CONCLUSION AND PRAYER

For the reasons discussed above, Appellee Marissa Ann Gonzales

respectfully requests that the Court grant her Motion for Extension of Time and

grant an additional 60 days in which to file her Brief, until April 17, 2015.

Respectfully submitted,

SAVRICK, SCHUMANN, JOHNSON, McGARR, KAMINSKI & SHIRLEY, LLP

,Ø/Wilson Shirley II / t.State Bar No. 00795647 Jessica Marcoux Hall State Bar No. 24046348 The Overlook at Gaines Ranch 4330 Gaines Ranch Loop, Suite 150 Austin, Texas 78735 512-347-1604 512-347-1676 Facsimile Email: wilson@ssjmlaw.com Email: jessica@ssimlaw.com ATTORNEYS FOR APPELLEE

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AGREED:

WASOFF & COWART, PLLC

Al r kovA }JA± Thomas B. Cowart State Bar No. 00787295 100 North Central Express Suite 901 Richardson, Texas 75080 214-692-9700 214-692-1979 Facsimile Email: torn@tcowart. corn ATTORNEY FOR APPELLANTS

CERTIFICATE OF CONFERENCE

I certify that I have conferred with Thomas Cowart, counsel for Appellants, by telephone on January 27, 2015 and he stated that he agrees to this Motion for Extension of Time to File Appellee’s Brief.

e sica Marcoux Hall

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Motion for Substitution of Counsel has been served on the following via the Efile system on this 2kiay of January, 2015:

Thomas B. Cowart, Via email: tom@tcowart.com WASOFF & Co WART, PLLC 100 North Central Expressway, Suite 901 Richardson, Texas 75080

ssica Marcoux all ‘

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