Stacey Scott v. Larry Furrow and Keller Williams Legacy Group

Opinion

ACCEPTED 04-15-00074-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 11/2/2015 9:03:24 AM KEITH HOTTLE CLERK

CAUSE NO. 04-15-00074-CV

FILED IN 4th COURT OF APPEALS IN THE COURT OF APPEALS FOR THE FOURTHSANCOURT ANTONIO, TEXAS OF APPEALS DISTRICT OF TEXAS, SAN ANTONIO, TEXAS 11/2/2015 9:03:24 AM KEITH E. HOTTLE Clerk

STACEY SCOTT, Appellant

vs.

LARRY FURROW AND KELLER WILLIAMS LEGACY GROUP, Appellees

ON APPEAL FROM THE 25™ JUDICIAL DISTRICT COURT OF GUADALUPE COUNTY, TEXAS CAUSE NO. 13-1125-CV-A

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLEES

TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS OF THE STATE OF TEXAS, SAN ANTONIO, TEXAS:

NOW COME LARRY FURROW and KELLER WILLIAMS LEGACY

GROUP, Appellees in this cause, and file this their Unopposed Motion for Extension

of Time to File Brief; and in support thereof would respectfully show this Honorable

Court as follows: . I.

Appellee's Brief is currently due on November 2, 2015. Appellant was

previously granted several unopposed extensions in which to file her brief. This is the

first request for an extension of the deadline for filing Appellees' Brief herein.

II.

In addition to the undersigned counsel's normally heavy trial and appellate

workload, counsel is involved in complex litigation pending in Cause No. 5-15-CV-

0284-RP in the Western District of Texas styled Nvision Biomedical Technologies,

LLC vs. JALEX Medical, LLC

III.

By reason of the foregoing, Appellees respectfully request of this Honorable

Court a 21-day extension until Monday, November 23, 2015 in which to file the Brief

ofAppellees in this matter. This extension of time will not work a hardship upon any

party, and will facilitate the presentation of briefs sufficient to apprise the Court of the

pertinent facts and law governing the issues at bar and to assist this Honorable Court

in a correct and complete resolution thereof.

IV.

Pursuant to Rule 10.1(a)(5), Tex. R. App. P., the undersigned counsel for

Appellees has conferred with Mr. Frederick Junldn, counsel for Appellant, who stated that he is not opposed to this motion.

This extension is not sought for delay only, but so that justice may be done.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray that

this Unopposed Motion for Extension to Time to File Brief be granted; and for such

other and further relief, at law or in equity, to which Appellees might show themselves

justly entitled.

Respectfully submitted,

THORNTON, BIECHLIN, SEGRATO, REYNOLDS & GUERRA, L.C. 100 N.E. Loop 410, Suite 500 San Antonio, TX 78216 Telephone: 210/342-5555; 210/525-0666 fax

By: sA^auehan E. Waters Vaughan E. Waters State Bar No. 20916700 ATTORNEYS FOR APPELLEES CERTIFICATE OF SERVICE

A true and correct copy of the above and foregoing instrument has been forwarded to the undersigned party on the 2nd day of November, 2015.

Via e-service

Mr. Frederick Junldn Andrews Kurth LLP 600 Travis St, Suite 4200 Houston'/TX 77002

Attorneys for Appellant.

sA^aughan E. Waters Vaughan E. Waters