Case Information

*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 8/24/2015 6:06:02 PM JEFFREY D. KYLE Clerk NO. 03-15-00261-CV THIRD COURT OF APPEALS 8/24/2015 6:06:02 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00261-CV *1 ACCEPTED ^[6631069] CLERK In the Third Court of Appeals Austin, Texas THOMAS D . YOUNG A / K / A T . DAVID YOUNG , APPELLANT v.

JP MORGAN CHASE BANK , N . A . , APPELLEE A PPEAL F ROM C AUSE N O . D-1-GN-12-000590 126 TH DISTRICT COURT OF TRAVIS COUNTY , TEXAS H ON . DARLENE BYRNE P RESIDING APPELLANT’S THIRD MOTION FOR EXTENSION OF TIME TO FILE

BRIEF ORAL C ASEY L AW O FFICE , P.C. ARGUMENT

595 Round Rock West Drive REQUESTED

Suite 102

stephen@caseylawoffice.us

Counsel for Appellant

Thomas D. Young a/k/a T. David Young

i *2

GROUNDS FOR MOTION 1. Appellant’s Brief is due to be filed in Court on August 24, 2015.

2. Appellant’s counsel lacks the clerk’s record.

3. Appellant’s counsel, upon discovery of the missing record, immediately

requested the record via phone call to the court. Appellant’s office left a message

with the court.

4. Appellant is asking for an extension until August 27, 2015, to permit receipt of

the clerk’s record and appropriate citation to the record in the brief.

5. This is Appellant’s third request for an extension. The previous two requests

(the first due to several concurrent brief deadlines, and the second due to a

family crisis) were graciously unopposed. This brief request is not for the

purposes of delay, is for three (3) days, and serves the interest of justice in having

the case considered on the merits of the appeal with appropriate citations to the

record.

PRAYER For the foregoing reasons, Appellant prays the Court will grant the motion.

Respectfully submitted, /s/ Stephen Casey 595 Round Rock West Drive, Suite 102 info@caseylawoffice.us *3 CERTIFICATE OF CONFERENCE I hereby certify that I noticed opposing counsel, Marcie L. Schout, via e-mail

on August 24, 2015. It was past 5:00 pm when the message was sent to Ms. Schout,

and opposing counsel did not have the opportunity to express any opinion on this

request.

/s/Stephen Casey CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing motion has

been served on Monday, August 24, 2015, on the following via electronic

transmission:

Marcie L. Schout

Quilling, Selander, Lownds,

Winslett, & Moser, P.C.

2001 Bryan Street, Suite 1800

Dallas, TX 75201

mschout@qslwm.com

/s/ Stephen Casey