Case Information
*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 8/18/2015 4:39:20 PM LISA MATZ Clerk *1 ACCEPTED 05-15-00380-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 8/18/2015 4:39:20 PM LISA MATZ CLERK N O . 05-15-00380-CV I N THE C OURT OF A PPEALS
F OR THE F IFTH D ISTRICT OF T EXAS D ALLAS , T EXAS
L UTHERAN S OCIAL S ERVICES OF THE S OUTH , I NC .
Appellant, v. INNIE B LOUNT , I NDIVIDUALLY AND AS N EXT F RIEND OF P.B., MINOR CHILD , AND
J OHN B LOUNT I NDIVIDUALLY AND AS EXT F RIEND OF P.B., MINOR C HILD
Appellees. O N A PPEAL FROM THE 192 ND J UDICIAL D ISTRICT OURT D ALLAS OUNTY T EXAS
CAUSE NO . DC-14-02429 PPELLANT UTHERAN OCIAL ERVICES OF THE S OUTH I NC .’ S B Darrell L. Barger Brian Rawson
State Bar No. 01733800 State Bar No. 24041754 Holly Naehritz
State Bar No. 08347475 State Bar No. 24083700
Kristina L. Culley H ARTLINE D ACUS B ARGER D REYER L.L.P.
State Bar No. 24069558 8750 N. Central Expressway, Suite 1600
H ARTLINE D ACUS ARGER D REYER L.L.P.
1980 Post Oak Blvd., Suite 1800 Telephone: 214-369-2100 Facsimile: 214-369-2118
Telephone: 713-759-1990 Email: brawson@hdbdlaw.com
Facsimile: 713-652-2419 hnaehritz@hdbdlaw.com
Email: dgreen@hdbdlaw.com
dbarger@hdbdlaw.com
kculley@hdbdlaw.com OUNSEL FOR *2 ’ S
Pursuant to Rule 10.5(b) of the Texas Rules of Appellate Procedure, Appellant
Lutheran Social Services of the South, Inc. asks this Court to extend the time to file its
Reply Brief and would show as follows:
1. Appellees are Winnie Blount, Individually and as Next Friend of P.B.,
minor child, and John Blount, Individually and as Next Friend of P.B., minor child. This motion is filed before the deadline for filing Appellant’s Reply Brief,
as required by Texas Rule of Appellate Procedure 38.6(d).
3. Appellee’s brief was filed on August 14, 2015 making Appellant’s Reply
Brief due on September 3, 2015. Texas Rule of Appellate Procedure 38.6 (c).
4. Appellant requests an extension of 15 days to file its Reply Brief, extending
the time until September 18, 2015.
5. No previous extensions by Appellant have been requested concerning its
Reply Brief.
6. Appellant requests an extension of time in which to file its Reply Brief in
order to allow time to adequately prepare its brief to aid the Court in consideration of this
appeal. In support of this motion, Appellant would state the following:
• Appellant requests an extension as appellant’s counsel has a number of time sensitive deadlines related to another appeal from a preliminary order from Bexar County, Texas which will require extensive briefing and input during the coming week; Appellant’s counsel has previously planned and made arrangements for an
out of state vacation during the week of August 25–September 1, 2015 which current due date falls almost immediately upon counsel’s return; *3 In addition to taking care of other immediate deadlines, counsel is also attending to personal family matters related to my son’s death this past March, including a family gathering out of town in San Antonio on Thursday, August 18. The undersigned has communicated with appellate counsel for the Appellee
who does not oppose this motion.
WHEREFORE, PREMISES CONSIDERED, Appellant Lutheran Social Services
of the South, Inc. requests this Honorable Court grant this Motion for Extension of Time
until September 18, 2015 to file its Reply Brief. ERTIFICATE OF ONFERENCE
I hereby certify that I have conferred with opposing appellate counsel, Jeff
Levinger, and he does not oppose the foregoing Appellant’s Motion for Extension of
Time to File Reply Brief until the requested date of September 18, 2015.
/s/ David W. Green David W. Green ERTIFICATE OF ERVICE
I hereby certify that a copy of the foregoing has been duly served upon counsel as
indicated below on this 18th day of August, 2015.
Muhammad S. Aziz BRAHAM ATKINS ICHOLS ORRELS GOSTO & RIEND
800 Commerce Street
Jeffrey S. Levinger EVINGER PC
1445 Ross Avenue, Suite 2500
/s/ David W. Green