No. 06-15-00017-CV

IN THE COURT OF APPEALS FOR THE 

SIXTH DISTRICT OF TEXAS 

AT TEXARKANA

BILLY FITTS and FREIDA FITTS,

Appellants,

v.

MELISSA RICHARDS-SMITH, THE LAW FIRM OF GILLAM & SMITH, 

LLP, E. TODD TRACY, and THE TRACY FIRM, Attorneys at Law,

Appellees.

On Appeal from the 71st District Court of Harrison County, Texas

Trial Court Cause No. 14-0150

UNOPPOSED MOTION FOR EXTENSION OF TIME

TO FILE BRIEF OF APPELLEES 

TO THE HONORABLE COURT OF APPEALS:

Melissa Richards-Smith and the Law Firm of Gillam & Smith, LLP

(Appellees) file this Unopposed Motion for Extension of Time to File Appellees’ 

Brief and would respectfully show:

Appellants filed their brief on June 8, 2015, making Appellees’ brief due on 

July 8, 2015. See Tex. R. App. P. 38.6(b). Appellees wish to extend that deadline 

by thirty days, or until August 7, 2015. See Tex. R. App. P. 38.6(b). This is 

Appellees’ first request for an extension of time to file its Appellees’ Brief. 

ACCEPTED

06-15-00017-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

6/26/2015 3:08:41 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 6/26/2015 3:08:41 PM DEBBIE AUTREY Clerk
This extension of time is necessary because the attorney primarily 

responsible for drafting the brief, Wade Crosnoe, will be on a previously scheduled 

vacation on the current filing deadline and the preceding holiday weekend. 

Additionally, Mr. Crosnoe’s work on other cases will prevent him from preparing 

the brief by the current deadline, including (1) drafting of post-submission briefing 

invited by the Court in an appeal styled Allstate Insurance Co., et al. v. Michael 

Kent Plambeck, D.C., et al., No. 14-10574, in the United States Court of Appeals 

for the Fifth Circuit; and (2) work on various responses and replies in connection 

with a motion to compel discovery and a motion to strike objections, and 

attendance at the June 16, 2015 hearing on those motions, in a case styled Munif 

Ali Gattas Bultaif, et al. v. Bridgestone/Firestone, Inc., et al., Cause No. 04-6262-

J, in the 191st District Court of Dallas County, Texas. 

Appellants Billy Fitts and Freida Fitts are not opposed to this motion.

Appellees E. Todd Tracy and the Tracy Firm are also unopposed.

For these reasons, Appellees respectfully request that the Court grant this 

motion and extend the deadline to file its Brief until August 7, 2015. Appellees 

also request all other relief to which it is justly entitled.

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Respectfully submitted,

THOMPSON, COE, COUSINS & IRONS L.L.P.

By: /s/ Wade Crosnoe

Wade C. Crosnoe

State Bar No. 00783903

701 Brazos, Suite 1500

Austin, TX 78701

Telephone: (512) 703-5078

Fax: (512) 708-8777

E-mail: wcrosnoe@thompsoncoe.com

Shawn W. Phelan

State Bar No. 00784758

Plaza of the Americas

700 N. Pearl Street, Twenty-Fifth Floor

Dallas, TX 75201-2832

Telephone: (214) 871-8245

Telecopy: (214) 871-8209

E-Mail: sphelan@thompsoncoe.com

Attorneys for Appellees Melissa RichardsSmith and Law Firm of Gillam & Smith, 

LLP

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CERTIFICATE OF SERVICE

I certify that a true and correct copy of this Unopposed Motion for Extension 

of Time to File Brief of Appellees was served on June 26, 2015, via electronic 

service or email, to the following counsel:

Lindsey M. Rames

Rames Law Firm, P.C.

5661 Mariner Drive

Dallas, TX 75237

Telephone: 214.884.8860

Facsimile: 888.482.8894

Email: lindsey@rameslawfirm.com

Carter L. Hampton

Hampton & Associates, P.C.

1000 Houston Street, Fourth Floor

Fort Worth, TX 76102

Telephone: 817.877.4202

Facsimile: 817.877.4204

Email: clhampton@hamptonlawonline.com

Attorneys for Appellants,

Billy Fitts and Freida Fitts

Bruce A. Campbell

Campbell & Chadwick

4201 Spring Valley Road, Suite 1250

Dallas, TX 75244

Attorney for Appellees E. Todd Tracy

and The Tracy Firm, Attorneys at Law

/s/ Wade C. Crosnoe

Wade C. Crosnoe

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