Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 11/12/2015 8:42:00 AM DEBBIE AUTREY Clerk *1 ACCEPTED 06-15-00024-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 11/11/2015 1:21:08 PM DEBBIE AUTREY CLERK
No. 06-15-00024-CV
————————— IN THE COURT OF APPEALS FOR THE SIXTH DISTRICT OF TEXAS AT TEXARKANA ——————————————————————————————
MONTY CLAY, ET AL.
Appellant
v. AIG AEROSPACE INSURANCE SERVICES, INC., ET AL. Appellee
——————————————————————————————
On Appeal from the 402 nd District Court of Wood County G. Timothy Boswell, Judge Presiding ——————————————————————————————
APPELLEE AIG AEROSPACE INSURANCE SERVICES, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF
——————————————————————————————
Appellee AIG Aerospace Insurance Services, Inc. f/k/a Chartis Aerospace Insurance Services, Inc. (“AIG”) files this Unopposed Motion for Extension of
Time to file its Appellee’s Brief, and would respectfully show the Court as
follows:
1. AIG’s Appellee’s Brief is currently due on December 4, 2015. 2. AIG seeks a 30-day extension in which to file its brief, such that its brief would be due on or before January 4, 2016. [1]
*2 3. AIG requests this extension because the undersigned, lead appellate counsel, has had or will have several deadlines that have interfered with his ability
to fully review and analyze the record prior to receiving Appellants’ brief, and that
will interfere with his ability to adequately prepare Appellee’s Brief by the current
deadline, including:
(a) Preparing for and participating in oral argument on October 13, 2015 in the Louisiana Third Circuit Court of Appeals in docket number 15-00461-CA,
styled: Hayward Allen, III v. PHI, Inc., et al ;
(b) Preparing Appellant’s Reply Brief in the United States District Court For the District Of Delaware in case number: 15-346-LPS, Bankruptcy Case No.
09-12261, Bankruptcy Adversary Proceeding Number 11-52423, which was filed
on November 2, 2015; and
(c) Preparing a Petition for Writ of Mandamus in Texas’ Tenth Court of Appeals in a case that will be styled In re Continental Motors, Inc., et. al. , which is
due on or before November 24, 2015.
4. In addition to the above-referenced deadlines, the undersigned was out of state from November 2-4, 2015 to assist an immediate family member
undergoing an emergency medical procedure, and will be traveling out of state
again for another procedure that will be set at some point in late November or early
December.
5. This extension is not sought for delay, but so that the undersigned can adequately prepare AIG’s brief.
6. The undersigned has conferred with lead appellate counsel for Appellants, who has stated that Appellants are not opposed to this motion.
Respectfully submitted, /s/ Steven D. Sanfelippo Steven D. Sanfelippo State Bar No. 24027827 CUNNINGHAM SWAIM, LLP 7557 Rambler Rd., Suite 440 Dallas, Texas 75231 (214) 646-1495
(214) 613-1163 - facsimile ssanfelippo@cunninghamswaim.com CERTIFICATE OF CONFERENCE The undersigned hereby certifies that he has conferred with counsel for Appellants, who has stated that Appellants do not oppose this motion for
extension.
/s/ Steven D. Sanfelippo Steven D. Sanfelippo *4 CERTIFICATE OF SERVICE On November 11, 2015, I served a copy of this document to the following counsel for Appellants Monty Clay, et al.
Michael A. Simpson
Simpson Boyd Powers & Williamson
P O Box 685
Bridgeport, TX 76426
D. Bryan Hughes
Law Office of D. Bryan Hughes
701 N Pacific Ave
Mineola, TX 75773
M. Keith Dollahite
M. Keith Dollahite, PC
5457 Donnybrook Ave
Tyler, TX 75703
Robert Waltman
Waltman & Grisham
2807 S Texas Ave, Ste 201
Bryan, TX 77802
William Angelley
Braden, Varner & Angelley, PC
703 McKinney Ave, Suite 400
Dallas, TX 75202
/s/ Steven D. Sanfelippo Steven D. Sanfelippo
[1] The 30 th day actually falls on Sunday, January 3, 2016.