Tami Donald, Jerry Moore, and Summit Spring Water Company, Inc. v. Brian Rhone, BMR Distributing, Inc., Chris Rhone, and Rhone Water Company, Inc. D/B/A Frosty's Water
Opinion
ACCEPTED 06-15-00052-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/10/2015 11:24:12 AM DEBBIE AUTREY CLERK
No. 06-15-00052-CV ___________________ FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS IN THE COURT OF APPEALS 12/10/2015 11:24:12 AM FOR THE SIXTH DISTRICT OF TEXAS DEBBIE AUTREY AT TEXARKANA Clerk _____________________________________________________________________________
TAMI DONALD, JERRY MOORE, and SUMMIT SPRING WATER CO., INC.
Appellants v.
BRIAN RHONE, CHRIS RHONE, BMR DISTRIBUTING, INC., and RHONE WATER CO., INC.
Appellees ______________________________________________________________________________
On Appeal from the 336th District Court of Fannin County, Texas The Honorable Laurine J. Blake, Judge Presiding ______________________________________________________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF ______________________________________________________________________________
I.
Appellees move for an unopposed extension of time to file their brief and state the following
in support:
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF PAGE -1- Appellees’ brief is due to be filed on December 14, 2015. Appellees respectfully request a
thirty-day extension of time, until January 13, 2016, to file their brief. Appellees have not previously
requested an extension of time to file their brief. Appellees are not filing this motion for the purpose
of delay, but in the interest of justice.
II.
Appellees’ counsel is Thomas F. Dunn. Mr. Dunn underwent a double disc spinal fusion
on October 16, 2015. His post operative recovery has limited the amount of time he has been able
to spend in the office to handle client matters. Consequently, Mr. Dunn’s client work load has been
jammed up. Due to the physical limitations on the amount of time he could spend on pending client
matters, Mr. Dunn will be unable to complete Appellees’ brief in this case by the December 14, 2015
deadline.
III.
WHEREFORE, PREMISES CONSIDERED, Appellees pray that this Court enter an order
granting their Unopposed Motion for Extension of Time to File Appellees’ Brief and specifying that
Appellees’ brief be filed on or before January 13, 2016.
Respectfully submitted,
/s/ Thomas F. Dunn Thomas F. Dunn State Bar No. 06243300 tomdunn@dunnlawgroup.net Dunn Law Group, P. C. 3901 W. Pioneer Parkway Arlington, Texas 76013 (817) 459-0000 (817) 459-0002 facsimile
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF PAGE -2- CERTIFICATE OF CONFERENCE
I certify that, on December 9, 2015, I conferred with Appellees’ counsel and he advised that
he is unopposed to the relief sought in this motion.
/s/ Thomas F. Dunn Thomas F. Dunn
CERTIFICATE OF SERVICE
I certify that, on December 10, 2015, I served a copy of this motion to the following counsel
for Appellants:
Chad M. Ruback The Ruback Law Firm 8117 Preston Road Suite 300 Dallas, Texas 75225
served via email to: chad@appeal.pro
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF PAGE -3-
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Tami Donald, Jerry Moore, and Summit Spring Water Company, Inc. v. Brian Rhone, BMR Distributing, Inc., Chris Rhone, and Rhone Water Company, Inc. D/B/A Frosty's Water (Tami Donald, Jerry Moore, and Summit Spring Water Company, Inc. v. Brian Rhone, BMR Distributing, Inc., Chris Rhone, and Rhone Water Company, Inc. D/B/A Frosty's Water) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.