Pursuant to Texas Rule of Appellate Procedure 38.6(d), Appellee, Barrett

Daffin Frappier Turner & Engel, LLP (“Barrett Daffin”) respectfully requests the

Court to extend time to file its brief by thirty (30) days to February 3, 2016. In

support thereof, Appellee Barrett Daffin shows as follows:

A. Introduction 1. The Clerk’s Record on Appeal was filed herein on September 4, 2015.

Appellants Michael Schuetz and Jamie Schuetz filed their brief on December 2,

2015.

2. Appellees CitiMortgage, Inc., individually and as successor by merger

to Source One Mortgage Services Corporation, and Mortgage Electronic

Registration Systems, Inc. obtained an extension of time to file their brief, making

their brief deadline on February 3, 2016.

3. Appellee Barrett Daffin’s brief is due on January 4, 2016

4. Appellee Barrett Daffin requests an extension of time to file

Appellee’s brief for thirty (30) days until February 3, 2016.

B. Facts and Basis for Relief 5. The Court has the authority under Texas Rule of Appellate Procedure

38.6(d) to extend the time to file Appellee’s Brief and no rule provides a deadline

to file this motion to extend. See T EX . R. A PP . P. 38.6(d).

6. No previous extensions have been granted to extend the time to file

Appellee’s Brief.

7. Counsel for Appellee Barrett Daffin, Mark D. Hopkins has multiple

appellate court deadlines during late December and early January. These include

the following:

a. December 28, 2015: Case No. 15-20201; Deutsche Bank National Trust Company, As Trustee v. Joanna and John Burke ; In the United States Court of Appeals for the Fifth Circuit – Reply Brief due.

b. January 11, 2015: Case No. 15-50881; Jillian Johnson v. World Alliance Financial Corp., et al .; In the United States Court of Appeals for the Fifth Circuit – Appellees’ Brief due.

8. Further, Counsel will be out of the office for a short period of time

over the holidays. Therefore, Counsel requests a short extension in order to

adequately devote the time necessary to all matters.

9. Counsel for Appellant and all counsel for Co-Appellees have

indicated that they are unopposed to this motion

C. Conclusion 10. Appellee Barrett Daffin, therefore, requests that its deadline to file

brief be extended until April 29, 2014, to give Appellee Barrett Daffin additional

time to adequately prepare its response.

D. Prayer

WHEREFORE, Appellee Barrett Daffin respectfully requests the Court to grant

an extension of time of thirty (30) days to February 3, 2016.

Respectfully submitted, By: _/s/ Mark D. Hopkins______ Mark D. Hopkins State Bar No. 00793975 Shelley L. Hopkins State Bar No. 24036497 Hopkins Law, PLLC 12117 Bee Caves Road, Suite 260 Austin, Texas 78738 (512) 600-4320 – Telephone (512) 600-4326 – Facsimile mark@hopkinslawtexas.com shelley@hopkinslawtexas.com A TTORNEYS F OR A PPELLEE CERTIFICATE OF CONFERENCE On December 15, 2015, I certify that I was to confer with counsel for

Appellant and counsel for Appellees, all of whom indicated they were unopposed

to this request for an extension.

_/s/ Mark D. Hopkins___________ Mark D. Hopkins *5 CERTIFICATE OF SERVICE I hereby certify that on December 16, 2015 , the foregoing Motion to Extend Time to File Appellee’s Brief has been forwarded to the following via

electronic filing :

Stephen Casey

info@caseylawoffice.us

CASEY LAW OFFICE, P.C.

595 Round Rock West Drive, Suite 102

Round Rock, Texas 78681

Counsel for Appellants

David Pfeuffer

dpfeuffer@nblawyers.net

BRAZLE & PFEUFFER, L.L.P.

170 E. San Antonio Street

New Braunfels, TX 78130

Counsel for Appellees (Fergusons)

B. David L. Foster

dfoster@lockelord.com

Susan A. Kidwell

skidwell@lockelord.com

Daniel Durell

Daniel.durell@lockelord.com

LOCKE LORD LLP

600 Congress Avenue, Ste 2200

Austin, TX 78701

Counsel for Appellees (CitiMortgage & MERS)

/s/ Mark D. Hopkins Mark D. Hopkins