Case Information
*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 9/24/2015 1:50:42 PM LISA MATZ Clerk *1 ACCEPTED 05-15-00910-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 9/24/2015 1:50:42 PM LISA MATZ CLERK No. 05-15-00910-CV In The
COURT OF APPEALS
FIFTH DISTRICT OF TEXAS Dallas, Texas David Cole, Independent Administrator of the
Estate of Kathryn Cole, Deceased Appellant, v.
Amica Mutual Insurance Company, Appellee.
On Appeal from Cause No. DC-15-02618-D In the 95th Judicial District Court of Dallas County, Texas
Honorable Ken Molberg, Presiding Judge APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE DALLAS COURT OF APPEALS:
Appellant David Cole Independent Administrator of the Estate of Kathryn Cole,
Deceased (“Appellant”), represented by Jo Allison Stasney of Thompson, Coe, Cousins
& Irons, L.L.P. (email address: jstasney@thompsoncoe.com) files this Unopposed
Motion for Extension of Time to File Appellant’s Brief and respectfully shows: The current deadline to file Appellant’s Brief is September 30, 2015.
2. Appellant seeks a 15-day extension of time to file its Brief. See Tex.
R. App. P. 38.6(d); 10.5 (b). Accordingly, Appellant seeks an extended deadline to
October 15, 2015.
3. This is Appellant’s first request for an extension of time to file its
Brief.
4. This extension of time is necessary due to the schedule of Appellant’s
lead appellate counsel, Jody Stasney. Specifically, her schedule prevents her from
preparing the Brief by the current deadline. Matters over the last few weeks being
handled by Ms. Stasney required immediate attention, including a federal court
removal with out-of-the-ordinary legal issues and finalizing settlements in a
seven-party insurance company lawsuit pending in federal court in Arizona
pursuant to the court’s September 2, 2015 order imposing a September 30, 2015
deadline, along with finalizing the settlement of a related bad faith action
pending in state court in Arizona. Additionally, Ms. Stasney has been attending
to personal matters involving the sale of her mother’s house in Fort Worth. Counsel for Appellant has personally communicated with counsel for
Appellee regarding this motion, and Appellee is not opposed to this motion and
the relief sought.
For these reasons, Appellant respectfully requests that the Court grant this
motion and extend the deadline to file Appellant’s Brief until October 15, 2015,
and grant any other relief to which it is justly entitled.
Respectfully submitted, ___ /s/ Jo Allison Stasney ___________ Jo Allison Stasney State Bar No. 19080280 THOMPSON, COE, COUSINS & IRONS, L.L.P. Plaza of the Americas 700 N. Pearl Street, Twenty-Fifth Floor Dallas, TX 75201-2832 Telephone: (214) 871-8200 Telecopy: (214) 871-8209 E-Mail: jstasney@thompsoncoe.com Wade C. Crosnoe State Bar No. 00783903 THOMPSON, COE, COUSINS & IRONS, L.L.P. 701 Brazos, Suite 1500 Austin, Texas 78701 Telephone: (512) 703-5078 Telecopy: (512) 708-8777 E-Mail: wcrosnoe@thompsoncoe.com COUNSEL FOR DAVID COLE, INDEPENDENT ADMINISTRATOR OF THE ESTATE OF KATHRYN COLE, DECEASED CERTIFICATE OF SERVICE This is to certify that on the 24th day of September, 2015, a copy of the
foregoing was sent via electronic notice and/or certified mail, return receipt
requested to Appellee’s counsel as follows:
Neil A. Bickley
Attorney at Law
301 S. Sherman, Suite 103
Richardson, TX 75081
s/ Jo Allison Stasney _______________ Jo Allison Stasney