Case Information
*0 FILED IN 2nd COURT OF APPEALS FORT WORTH, TEXAS 12/13/2017 11:13:56 AM DEBRA SPISAK Clerk *1 ACCEPTED 02-17-00313-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 12/13/2017 11:13 AM DEBRA SPISAK CLERK No. 02-17-00313-CV
IN THE COURT OF APPEALS
FOR THE SECOND JUDICIAL DISTRICT
FORT WORTH, TEXAS
__________________________________________________
THOMAS FLORENCE,
Plaintiff-Appellant,
v.
K. ROLLINGS, et al.
Defendants-Appellees.
_________________________________________________
On Appeal from the 78th Judicial District Court
Wichita County, Texas
Trial Court Cause No. 186,279-B
_________________________________________________
APPELLEES K. ROLLINGS AND A. FRANCO’S
MOTION FOR EXTENSION OF TIME
TO FILE APPELLEES’ BRIEF KEN PAXTON LACEY E. MASE
Attorney General of Texas
Chief, Law Enforcement Defense
JEFFREY C. MATEER Division
First Assistant Attorney General
*AMBER MCKEON-MUELLER
BRANTLEY STARR Assistant Attorney General
Deputy First Assistant Texas Bar No. 24088027
Attorney General Office of the Attorney General
Post Office Box 12548
JAMES E. DAVIS Austin, Texas 78711-2548
Deputy Attorney General for (512) 463-2080 / (512) 370-8914
Defense Litigation amber.mckeon-mueller@oag.texas.gov
* Counsel of Record
TO THE HONORABLE JUDGES OF THIS COURT OF APPEALS:
Under the authority of Texas Rules of Appellate Procedure 10.5(b)(1) and
38.6(d), Appellees, K. Rollings and A. Franco, move for an extension of time to file
Appellees’ Brief in the above styled and numbered case.
I.
Appellees’ brief is currently due on December 18, 2017. This is the first
extension sought by Appellees in this appeal. Appellees, K. Rollings and A. Franco,
seek a 30-day extension of time to file its brief, to and including January 17, 2018.
Counsel for Appellees was in trial on the date that Appellant Florence filed his brief.
Counsel for Appellees is in trial beginning on December 13, 2017. Within the 30
days between now and January 17, 2018, counsel for Appellee has another appellate
brief due, two motions for summary judgment due, and vacation planned for the
holidays. An extension is requested so that counsel may have adequate time to
review the clerk’s and reporter’s records, her own records, Appellant’s brief, and file
a thorough brief, thereby preserving judicial economy. Therefore, Appellees
respectfully requests a 30-day extension to file Appellees’ brief.
Therefore, Appellees respectfully pray the Court extends the deadline for the
filing of Appellees’ Brief to and including January 17, 2018.
Respectfully submitted,
KEN PAXTON
Attorney General of Texas
JEFFREY C. MATEER
First Assistant Attorney General
BRANTLEY STARR
Deputy First Assistant Attorney General
JAMES E. DAVIS
Deputy Attorney General for Defense
Litigation
LACEY E. MASE
Assistant Attorney General
Chief, Law Enforcement Defense Division
/s/ Amber McKeon-Mueller
AMBER McKEON-MUELLER
Assistant Attorney General
Attorney-in-Charge
Texas Bar No. 24088027
amber.mckeon-mueller@oag.texas.gov
Office of the Attorney General
Post Office Box 12548
Austin, Texas 78711-2548
(512) 463-2080 / (512) 370-9814
ATTORNEYS FOR APPELLEES
CERTIFICATE OF CONFERENCE
I, Amber McKeon-Mueller, am unable to confer with Appellant Florence,
who is an incarcerated individual.
/s/ Amber McKeon-Mueller
AMBER McKEON-MUELLER
CERTIFICATE OF SERVICE
I, Amber McKeon-Mueller, certify that a true and correct copy of the above
and foregoing Appellees K. Rollings and A. Franco’s Motion for Extension of
Time has been served by placing same in the United States Postal Service, postage
prepaid, on December 13, 2017, addressed to:
Thomas Florence
TDCJ-CID #01729344
James V. Allred Unit
2101 FM 369 North
Iowa Park, TX 76367
/s/ Amber McKeon-Mueller
AMBER McKEON-MUELLER