Case Information
*0 FILED IN 2nd COURT OF APPEALS FORT WORTH, TEXAS 12/20/2017 3:27:59 PM DEBRA SPISAK Clerk *1 ACCEPTED 02-17-00374-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 12/20/2017 3:27 PM DEBRA SPISAK CLERK
N O . 02-17-00374-CV
_______________
In the
Court of Appeals
For the Second District of Texas
Fort Worth
_______________
Joseph Lambert and Susan Lambert,
Appellants ,
v.
State Farm Lloyds and Tevin Senne,
Appellees.
_______________
On Appeal from the 415th Judicial District Court
of Parker County, Texas
No. CV16-0048
_______________
First Unopposed Motion to Extend Time
to File Appellants’ Brief
_______________
Appellants Susan and Joseph Lambert file this first unopposed
motion for extension of time under Texas Rule of Appellate Procedure
10.5(b) and respectfully request a 30-day extension of time, until
February 3, 2018, to file their brief.
I.
This is an appeal from a Final Judgment signed on September 29,
2017, by the Honorable Graham Quisenberry, in the 415th Judicial
District Court of Parker County, Texas, in Cause No. CV16-0048.
Appellants filed a notice of appeal on October 27, 2017. A complete
record was filed on December 6, 2017. Appellants’ brief is currently due
on January 4, 2018. This is Appellants’ first request for an extension of
time.
II.
This motion is not filed for the purpose of delay. Appellants’
counsel respectfully requests this extension of time to ensure ample
opportunity to review the record and prepare Appellants’ brief.
Appellants’ counsel has also been substantially involved in the following
matters, among others, that necessitate the filing of this motion:
Richard Seim and Linda Seim v. Allstate Texas Lloyds
and Lisa Scott , No. 17-0488; In the Supreme Court of
Texas. Counsel must prepare and file Petitioner’s Reply
in Support of Petitioner’s Brief on the Merits by December
27, 2017; and
Sherilyn Leroux v. NCL (Bahamas), Ltd. , No. 17-13877; In
the United States Court of Appeals for the Eleventh
Circuit. Counsel must prepare and file Appellant’s Brief
by December 29, 2018.
PRAYER
Appellants Susan and Joseph Lambert respectfully request that the
Court grant this motion and extend the time for filing their brief to
February 3, 2018, and to grant any other relief to which Appellants may
be entitled.
Respectfully submitted,
T HE B ENDER L AW F IRM PLLC
By: /s/ Andrew B. Bender
Andrew B. Bender
Texas Bar No. 24084290
1911 Southwest Fwy
Houston, TX 77098
Tel. 832.754.6921
Fax. 832.916.3239
abender@thebenderfirm.com
Chad T. Wilson
Texas Bar No. 24079587
cwilson@cwilsonlaw.com
Kimberly N. Blum
Texas Bar No. 24092148
kblum@cwilsonlaw.com
455 E. Medical Center Blvd., Suite 555
Webster, Texas 77598
T: 832.415.1432
F: 281.940.2137
A TTORNEYS FOR A PPELLANTS
CERTIFICATE OF CONFERENCE
In accordance with Rule 10.1(a)(5) of the Texas Rules of Appellate
Procedure, I certify that I conferred with Melissa Lorber, counsel for
Appellees, who stated that she is unopposed to the relief requested in
this motion.
/s/ Andrew Bender
CERTIFICATE OF SERVICE
In accordance with the Texas Rules of Appellate Procedure, I certify
that a true and correct copy of this First Unopposed Motion to Extend
Time to File Appellants’ Brief was served on all counsel of record in
accordance with the Texas Rules of Appellate Procedure on December
20, 2017.
/s/ Andrew Bender