Case Information
*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/24/2015 3:29:44 PM JEFFREY D. KYLE Clerk
*1 ACCEPTED 03-15-00384-CV 7976738 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/24/2015 3:29:44 PM JEFFREY D. KYLE CLERK NO. 03-15-00384- V § C RY TAL BI NGHAM H ERNANDEZ IN THE COU I~T OF APPEAL Appellant § vs. § FOR THE §
TIFFANY POLLEY § THIRD DISTRICT OF TEXA Appellee MOTION TO EXTEND TIME TO FILE APPELLANT' REPLY BRI EF TO THE HONORABLE JU TICES OF AID COURT:
Now comes CRY TAL BING II AM II ERNANDEZ, Appellant in the above styled and numbered cause. and moves this Court to grant an extension of time to tile Appellant's reply brief. pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure. and for good cause shows the folio" ing:
I. Thi case is on appeal from the County Court at Law No.2 of Tom Green County. Texas. 2. The case below "'as st) led Cr) sta l Bingham I krnandez '. Tiffan) Polle) , and numbered 12C482-L2. 3. Notice of Appeal was fi led with this Court on June 24, 2015. 4. The C lerk's Record wa tiled "'ith this Court on July 13. 2015. The Reporter's
Record was fil ed wi th this o ur1 o n Ju ly 22. 20 15. 5. Appellant's brief was tiled on eptember 18. 2015. 6. Appellee's responsive briefwas fil ed o n November 18.2015. 7. Appel lant' s rcpl) brief is due on December 8. 2015. 8. Appel lant req uests a 30-da) C. tension rrom the present dead line of December 8.
20 15 to January 7. 20 16. *2 9. No extension to fi le the Appellant" s repl) brief has been requested or received in thi s cause. I 0. Appellanf s counse l re lies on the following facts as good cause for the requested extension: Counsel lo r Appellant has an ex tensive cascload of civil. criminal and fami ly cases pendi ng in various coun ty and district co urts. For this reason and because of the upcoming Thanksgiving hot ida), Counse l for Appellant req uests add iti onal ti me to research and fi le Appell ant's response brief.
WH EREFORE, PREM ISES CONSIDERED. Appellant pra)s that thi s Court grant this Motion to Extend Time to File ppellant's Rep!) Brief. and for such other and further relief as the Court may deem appropriate.
Respectful ly submitted, The Law Offices of Jlick DeHoyos 502 outh Irving Street
an Angelo. Texas 76903 rick a dcho' o~lav. li nn.wm Tel: (325) 658-8000 Fax: (325) 227-69 13
~ ~o:fvo;- 4 - t"" c;::: tate Bar No. 05644085 ATTORNEY FO R APP ELLANT CERT I FI CATE OF CONFERENCE Thi s is to certi fy that on November 2C/-h-. 20 15, I contacted Ms. Lorin M. ubar, Allorney for Appell ee. and di scussed this motion with her. and she is NOT OPPOS · D to th is moti on.
CERTIFI CATE OF ERVI CE
*3 1 hereby certify that a true and correct copy of the foregoing Motion to Extend Time to File Appellant's Brief was served on all counsel or record on thi s ~ ay of November. 20 15. as follows: Via Fru: Transmission: (214) 736-9994 Lorin M., ubar The Willis Law Group, PLLC I 0440 N. Central Expy .. Suite 520 Dallas. TX 75231