Case Information

*0 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 11/2/2015 1:40:43 PM PAM ESTES Clerk *1 ACCEPTED 12-15-00047-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 11/2/2015 1:40:43 PM Pam Estes CLERK

Cause No. 12-15-00047-CV

IN THE COURT OF APPEALS

FOR THE TWELFTH JUDICIAL DISTRICT

TYLER, TEXAS

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MARK J. HEALEY

APPELLANT

EDWIN N. HEALEY

APPELLEE

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On Appeal from Cause No. 2014C-0638

From the 3 rd District Court, Henderson County, Texas

Honorable Mark Calhoon, Judge Presiding

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MOTION TO EXTEND TIME FOR FILING APPELLANT'S BRIEF

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TO THE HONORABLE JUDGE OF SAID COURT:

Now comes Appellant is Mark J. Healey and moves the Court for an extension of

time to November 30, 2015 to file his Reply Brief and in support thereof, would show the

Court:

II.

The Appellant’s brief without extension is due November 10, 2015.

III.

A Reply Brief is needed in this cause to clearly present the issues to the Court.

IV.

Appellant’s attorney’s work schedule makes it extremely difficult to properly

prepare a Reply Brief within the 20 day period of the filing of Appellee’s Brief and

settlement discussions are in progress.

No previous extensions of time have been requested or granted for Appellant’s

Reply Brief.

VI.

Appellant’s attorney has conferred with Appellee’s attorney regarding this motion

and Appellee’s attorney does not oppose this motion.

WHEREFORE, Appellant moves the Court for an extension of time until

November 30, 2015 in which to file Appellant’s Reply Brief.

Respectfully submitted,

STARK & GROOM, LLP

110 E. Corsicana St.

Athens, TX 75751

903-675-5691 Telephone

903-675-6454 Facsimile

stevestark@starkandgroom.com Email

/s/ Steve Stark

State Bar No. 19066000

Attorney for Appellant

CERTIFICATE OF CONFERENCE

Appellant’s Attorney hereby certifies that he conferred with Koy Killen by

telephone on October 29, 2015 and counsel does not oppose the requested extension.

_/s/_ Steve Stark

CERTIFICATE OF SERVICE

I certify that on November 2, 2015 a true and correct copy of Appellant’s Motion

To Extend Time of Filing Reply to Appellee’s Brief was served on all parties or counsel

of record in accordance with rules.

Koy R. Killen Via Fax: 817-447-0052

104 South Main Street

Burleson, Texas 76028

Paul C. Healey

3309 Heather Hill

Garland, Texas 75044

_/s/_