Case Information
*0 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 12/21/2015 3:10:09 PM PAM ESTES Clerk *1 ACCEPTED 12-15-00119-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 12/21/2015 3:10:09 PM Pam Estes CLERK NO. 12-15-00119-CV IN THE TWELFTH COURT APPEAIS TYLERTEXAS DEBR¿.DENTLE.AI AIK/A
DEBBIE D. LEAI, AND TANGO
TRÂNSPORT, INC., AND TANGO
TRANSPORT, TT,C.
vs
JAMES JORDAN
Appealed 115ù District Court Upshut County, Texas Cause No. 588-12 Honotable Lauten Parish, Ptesiding Judge MOTION EXTEND TIME, FOR "Rust''Phenix Bar
PHENIX &
P. O. Box
Ilenderson, Texas
903.657.3595
903.657 .3598 - Facsimile
ATTORNEY FOR APPF'J J EE
MOTION TO EXTEND TIME FOR THE HONORABLE COURT:
Now comes Appellee,JAMESJORDAN, who makes and files this Motion to Extend Time for
Filiog of Âppellee's Brief for such would show the Court the following:
7.
The cunent deadline for fi.ling Appellee's Bdef is January 4,2076. Appellant's Brief filed
on Decemb er 2,2075 this date is calculated allowing fot additional the thirty deadline
ftom the fiting of Brief expires Saturday,January 2,2016. '\ppellant's
2.
Appellee requests the Court graît a thirty (30) day extension.
3.
Appellee requests extension time fot the following reasons:
a.. Appellee's counsel has been unusually busy during the first part of Decembet
with hearings and yeat end business;
b. Appellee's counsel has a planned vacation Decernber 24,2015 through
January 4,2076;and.
c. The staff of Appellee's counsel will also be vacationing during that time the
holidays.
Thetefote, Appellee's will have his normal staff avatlable to ptepare, complete, and
file Appellee's Brief dudng the time from December24,2075 toJanuzry 4,201,6.
4.
This is first extension tequested by,\ppellee's counsel. This request for the extension is not
sought delay only, but that justice may be done.
CERTIFICATE CONFERENCE Appellee's counselhas conferedwithAppellant's counselbyphone December27,2075,and informed that Appellant's does oppose the requested extension.
WHEREFORE,PREMISES CONSIDERED,JAMESJORDAN,,{.ppellee,requests theCourt
to extend the time filing his bdef in this mattet by thitty (30) to February 4,2076. Appellee
requests such othet further telief which Appellee may be jusdy entitled for which Appellee
will evet ptay.
Resp ectfu lly submitted, PHE,NIX & 118 S. MAIN POST OF'F'ICE, BOX 1OO5 HE,NDE,RSON, TEXAS 7 903/6s7-3s9s 903 / 6s7 -3598 - FACSTMTLE BY: /s/ T. R. "Rustv" Phenix J. R. "RUSTY" PHENIX Bat Attomey Appellee, tames lotdan CERTIFICATE OF SERVICE I hereby certifir thatz true and coffect copy of the above and fotegoinghas been forwatded on the 21"' Decemb.g 2075 zddressed/ditected follows:
Matthew Thigpen
I-ADD & THIGPE,N, P.C.
235 S. Btoadwty, Suite 200
Tylet, Texas 75702
Facsimile: / 7 05-7
R.' "RUSTY" PHENIX