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Brooke Bruce// Carter Bruce v. Carter Bruce// Cross-Appellee, Brooke Bruce
03-16-00581-CV
| Tex. App. | Nov 17, 2016
|
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Case Information

*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/17/2016 2:22:14 PM JEFFREY D. KYLE Clerk THIRD COURT OF APPEALS 11/17/2016 2:22:14 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-16-00581-CV *1 ACCEPTED [13853976] CLERK N O . 03-16-00581-CV

I N T HE T HIRD C OURT OF A PPEALS A USTIN , T EXAS B ROOKE B RUCE , Appellant, v.

C ARTER B RUCE , Appellee.

On Appeal from the 345 th Judicial District Court of Travis County, Texas

Trial Court Cause No. D-1-FM-06-002028 PPELLANT State Bar No. 24069638 D UDLEY L AW , PLLC 1717 West Sixth Street, Suite 315 Austin, Texas 78703 (512) 617-3975 (telephone) (512) 479-7910 (facsimile) kdudley@dudley-law.com C OUNSEL FOR *2 TO THE HONORABLE THIRD COURT OF APPEALS IN AUSTIN, TEXAS:

Appellant Brooke Bruce (“Appellant”) files this First Motion for Extension of

Time to File Petition for Review under T EX . R. PP . P. 10.1, 10.5(b), and 38.6(d),

and in support thereof would respectfully show the following:

1. Appellant’s Brief is currently due on Monday, November 21, 2016.

Appellant requests an extension of time of thirty days, to December 21, 2016. This

is Appellant’s first request for an extension of time in this case.

2. The extension will permit counsel to fully analyze the record and

relevant law and thus prepare thorough briefing to aid the Court in its consideration

of this appeal: to conduct additional legal research as appropriate, and to include

such additional factual and legal support in the briefing to present to this Court.

3. In addition to preparing the briefs in this case, counsel for Appellant,

who is the sole attorney in her law practice, has recently devoted time to discovery

responses in two different matters due November 11 and November 15, various

hearings, mediations and attending a seminar in addition to the other legal and

administrative responsibilities of managing a law practice.

4. The undersigned has attempted to confer with opposing counsel, who

has not yet responded. This extension is not sought for delay, and no party will be

prejudiced if it is granted. *3 For the foregoing reasons, Appellant respectfully requests that the Court grant

this thirty-day extension to file her brief, creating a new deadline of December 21,

2016.

Respectfully submitted, D UDLEY L AW , PLLC 1717 West Sixth Street, Suite 315 Austin, Texas 78703 (512) 617-3975 Telephone (512) 479-7910 Facsimile By: /s/ Kacy L. Dudley Kacy L. Dudley State Bar No. 24069638 kdudley@dudley-law.com CERTIFICATE OF CONFERENCE As required by T EX . R. PP . P. 10.1(a)(5), I certify that via email on November

17, 2016, I attempted to confer with Ms. Cecilia Wood, counsel for CARTER

BRUCE, who has not yet indicated whether this motion is opposed.

/s/ Kacy L. Dudley CERTIFICATE OF SERVICE *4 I hereby certify that a true and correct copy of the foregoing document was

served in accordance with the Texas Rules of Appellate Procedure on Thursday,

November 17, 2016 as follows:

Cecilia M. Wood

919 Congress Ave., Ste. 830

Austin, Texas 78701

Via Email: Cecilia@ceciliawood.com

Attorney for Carter Bruce

/s/ Kacy L. Dudley

Case Details

Case Name: Brooke Bruce// Carter Bruce v. Carter Bruce// Cross-Appellee, Brooke Bruce
Court Name: Court of Appeals of Texas
Date Published: Nov 17, 2016
Docket Number: 03-16-00581-CV
Court Abbreviation: Tex. App.
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