Robyn N. Jones v. Wells Fargo Bank, N.A.

• Court: Court of Appeals of Texas
• Decided: January 2, 2015
• Docket: 03-14-00658-CV
• Status: Published

Opinion

ACCEPTED 03-14-00658-CV 3634773 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/2/2015 10:56:48 AM JEFFREY D. KYLE CLERK

NO. 03-14-00658-CV FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 1/2/2015 10:56:48 AM JEFFREY D. KYLE In The Clerk

Third Court of Appeals ____________________________________________________________________

ROBYN N. JONES, Appellant, v. WELLS FARGO BANK, N.A., Appellee. ____________________________________________________________________

Cause No. 11-0479 On Appeal from the 428th District Court, Hays County, Texas Honorable Bill Henry, Judge Presiding ____________________________________________________________________

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF ____________________________________________________________________

TO THE HONORABLE THIRD COURT OF APPEALS:

Pursuant to Rules 10.5(b) and 38.6(d), TEX. R. APP. P., Appellee Wells

Fargo Bank, N.A. respectfully moves this Court to extend the time for filing its

Appellee’s Brief by 30 days to February 10, 2015.

1. Background: Appellant’s Brief was filed on December 12, 2014.

Appellee’s Brief is therefore due on January 11, 2015. 2. Grounds for the extension: Due to the Christmas holidays, Appellee’s

counsel’s travel plans, and a number of other engagements, Appellee’s counsel

needs an additional 30 days to prepare Appellee’s brief.

3. Unopposed: Counsel for Appellant has stated that Appellant does not

oppose this Motion.

4. Number of extensions: This is Appellee’s first request for an

extension of time for the filing of its Appellee’s Brief.

PRAYER

Appellee prays that this Motion be granted and that the time for filing its

Appellee’s Brief be extended by 30 days to February 10, 2015. Appellee also

prays for such other and further relief to which it may be entitled at law or in

equity.

2 Respectfully submitted,

LOCKE LORD LLP

By: /s/ Ryan D. V. Greene B. David L. Foster dfoster@lockelord.com State Bar No. 24031555 Ryan D. V. Greene rgreene@lockelord.com State Bar No. 24012730 600 Congress Avenue, Suite 2200 Austin, Texas 78701 Telephone: (512) 305-4700 Facsimile: (512) 305-4800

W. Scott Hastings shastings@lockelord.com State Bar No. 24002241 Robert T. Mowrey rmowrey@lockelord.com State Bar No. 14607500 2200 Ross Avenue, Suite 2200 Dallas, Texas 75201 Telephone: (214) 740-8000 Facsimile: (214) 740-8800

Counsel for Appellee Wells Fargo Bank, N.A.

3 CERTIFICATE OF CONFERENCE

I hereby certify that counsel for Appellee, Ryan D. V. Greene,

communicated on December 23, 2014 by email with Doug W. Ray (counsel for

Appellant), and that Mr. Ray has informed Mr. Greene that this motion is

unopposed.

/s/ Ryan D. V. Greene Ryan D. V. Greene

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was served on the following counsel of record by the CM/ECF system or, if any counsel is not registered, by United States mail on this the 2nd day of January, 2015:

Doug W. Ray Ray & Wood 2700 Bee Caves Road Austin, Texas 78746

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