Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 12/18/2015 2:30:26 PM DEBBIE AUTREY Clerk *1 ACCEPTED 06-15-00042-cv SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/18/2015 2:30:26 PM DEBBIE AUTREY CLERK No. 06-15-00042-CV
IN THE SIXTH COURT OF APPEALS
WACO, TEXAS
ALLSTATE INSURANCE COMPANY,
Appellant/Cross-Appellee, v.
MARGARET JORDAN,
Appellee/Cross-Appellant.
ON APPEAL FROM THE 170th JUDICIAL DISTRICT COURT
OF MCLENNAN COUNTY, TEXAS, NO. 2014-243-4
J O I NT M O T I ON F OR
E X T E N S I ON OF T I ME TO F I LE B R I E FS
TO THE HONORABLE JUDGE OF SAID COURT:
Appellant/Cross-Appellee, Allstate Insurance Company ("Allstate"), and
Appellee/Cross-Appellant, Margaret Jordan ("Jordan") file this Joint Motion to Extend
Time to File Briefs and would show this Court the following:
1. Allstate's and Jordan's appellate briefs are due on Wednesday, December 30,
2015. Allstate and Jordan request an extension of thirty (30) days, or until January 29,
2016, to file their briefs.
2. Jordan's counsel has a pre-paid vacation during the Christmas holidays and
needs additional time to review the appellate record and prepare Jordan's brief. Allstate's
JOINT MOTION FOR EXTENSION OF TIME TO F I LE BRIEFS - PAGE 1
counsel has a brief due in another case on December 28, 2015. She will also need
additional time to review the appellate record in this case and prepare Allstate's brief.
Therefore, Allstate joins this request for an extension of time to file its brief as well.
3. This is the parties' first request for extension of time to file their briefs.
4. For these reasons, Allstate and Jordan respectfully request an extension of
time until January 29, 2016, to file their appellate briefs. Allstate and Jordan also request
such other and further relief to which they are justly entitled.
Allstate and Jordan pray that the Court grant this Joint Motion for Extension of
Time. They also pray for such other relief to which they may be justly entitled.
Respectfully submitted,
/s/Jacquelyn Chandler
Jacquelyn Chandler
State Bar No. 24001866 Roger D. Higgins
State Bar No. 09601500 THOMPSON, COE, COUSINS & IRONS, L.L.P.
700 North Pearl Street, 25 th Floor
Dallas, Texas 75201
Telephone: (214) 871-8200
Facsimile: (214) 871-8209
Email: jchandler@thompsoncoe.com
Email: rhiggins@thompsoncoe.com
John M. Causey
State Bar No. 04019100
P. O. Box 3188
Conroe, Texas 77305-3188
(936) 441-4673 - Metro
(93 6) 441 -4674 - Telecopier
Email: John@hope-causey. com
A T T O R N E YS F OR A P P E L L A N T/
C R O S S - A P P E L L EE
A L L S T A TE I N S U R A N CE C O M P A NY
/s/David G. Tekell (**w/permission)
David G. Tekell
State Bar No. 19763950 T E K E LL & A T K I N S, L . L . P.
P. O. Box 23248
Waco, TX 76702-3248
Telephone: 254-776-5095
Facsimile: 254-776-5091
Email: david@tekellatkins.com
A T T O R N EY F OR A P P E L L E E/
C R O S S - A P P E L L A NT
M A R G A R ET J O R D AN
C E R T I F I C A TE OF S E R V I CE
I certify that a true and correct copy of the foregoing document was sent to all
counsel of record via electronic notice and/or certified mail, return receipt requested on this
18th day of December, 2015.
By: /s/Jacquelyn Chandler
Jacquelyn Chandler
STATE OF TEXAS §
§
COUNTY OF DALLAS §
BEFORE ME, the undersigned notary public, on this day personally appeared
Jacquelyn Chandler who being by me first duly sworn, on her oath, deposed and said that
she is the lead appellate counsel for Allstate Insurance Company, Appellant/Cross-
Appellee, in this case, and that she has read this Joint Motion for Extension of Time to
File Briefs and that the statements contained within are, based upon information and
belief, true and correct.
SUBSCRIBED AND SWORN TO BEFORE ME by Jacquelyn Chandler on this
the 18th day of December, 2015, to certify which witness my hand and official seal.
Notary Public, State of Texas My Commission Expires: ^ - f l -H