No. 06

- 15

- 00017

- CV

IN THE COURT OF APPE ALS FOR THE SIXTH DISTRICT OF TE XAS 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

UN OPPOSED 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 Ext ension of Time to File Appellee s’
Brief and would respectfully show:
Appellants filed their brief o n June 8, 2015, making Appellee s’ 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
Appellee s’ first request for an extension of time to file its Appellee s’ Brief. ACCEPTED 06-15-00017-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/26/2015 3:08:41 PM DEBBIE AUTREY

CLERKThis 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.

Additionall y, 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 C ourt 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 heari ng 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.
Appell ants Billy Fitts and Frei da Fitts are not opposed to this moti on.
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. Appellee s
also request all other relief t o which it is justly entitled.

2Respectfully 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

Attorney s for Appellees Melissa Richards

Smith and Law Firm of Gillam & Smith, LLP

3C ER T IFICATE OF S E RVI C E 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, 201 5 , 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 Ro ad, 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

4