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No. 03-15-00280-CV 

In the Third Court of Appeals 

Austin, Texas 

_______________________________________________ 

Michael J. DeLitta, 

 Appellant 

v. 

Nancy Schaefer 

 Appellee 

_______________________________________________ 

UNOPPOSED MOTION FOR EXTENSION OF TIME

_____________________________________________________ 

TO THE HONORABLE THIRD COURT OF APPEALS: 

Pursuant to Texas Rules of Appellate Procedure 38.6(d) and 10.5(b), Appellee 

Nancy Schaefer files this motion for extension of time and would respectfully show the 

Court as follows: 

I. 

Appellant filed his brief on June 10, 2015. In this accelerated appeal, Appellee’s 

brief currently is due on Tuesday, June 30, 2015. Appellee requests that the Court grant 

a 20-day extension of time by which to file her brief. Granting this motion would 

make the brief due on July 20, 2015. 

ACCEPTED

03-15-00280-CV

5716292

THIRD COURT OF APPEALS

AUSTIN, TEXAS

6/17/2015 3:08:56 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 6/17/2015 3:08:56 PM JEFFREY D. KYLE Clerk
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II. 

Tragedy has struck the TAYLOR, DUNHAM AND RODRIGUEZ family, as David 

Dunham’s young son died unexpectedly. While Mr. Dunham is not counsel of record 

in this appeal, the sad situation has created uncertainty in the small firm’s docket. 

Additional time would allow the partners to support each other during this difficult 

time, personally and professionally. 

This extension is not sought for delay and is Ms. Schaefer’s first request for 

extension of time in this case. 

Appellant, through counsel, indicates that he does not oppose the relief sought 

in this motion. 

PRAYER

Appellee Nancy Schaefer asks the Court to grant her a 20-day extension, making 

her brief due on July 20, 2015. Appellee also prays for any and all further relief to which 

she may be entitled. 

 
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Dated: June 17, 2015 Respectfully submitted, 

 By: /s/ Lisa Bowlin Hobbs 

Donald R. Taylor 

 State Bar No. 19688800 

 dtaylor@taylordunham.com 

Of Counsel Stacey Reese 

 State Bar No. 24056188 

 stacey@reeselawpractice.com 

TAYLOR DUNHAM & RODRIGUEZ LLP 

301 Congress Avenue, Suite 1050 

Austin, Texas 78701 

(512) 473-2257 

(512) 478-4409 (fax) 

Lisa Bowlin Hobbs 

 State Bar No. 24026905 

 Lisa@KuhnHobbs.com 

Kurt Kuhn 

 State Bar No. 24002433 

 Kurt@KuhnHobbs.com 

KUHN HOBBS PLLC 

3307 Northland Drive, Suite 310 

Austin, Texas 78731 

(512) 476-6003 

(512) 476-6002 (fax) 

 Howard F. Carter, Jr., 

 State Bar No. 03916500 

 sam@scarterlawfirm.com 

HOWARD F. CARTER, JR., P.C. 

5600 Tennyson Parkway, Suite 160 

Plano, Texas 75024 

(972) 455-2001 

(972) 455-2015 (fax) 

CERTIFICATE OF CONFERENCE

 Pursuant to Texas Rule of Appellate Procedure 10.1, I certify that, on June 16, 

2015, I conferred with Douglas R. Drucker, counsel for Appellant, regarding this 

motion via email. Mr. Drucker indicated that he is not opposed to the relief requested. 

 /s/ Lisa Bowlin Hobbs 

 Lisa Bowlin Hobbs 
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CERTIFICATE OF SERVICE

 I hereby certify that, on June 17, 2015, and in compliance with the Texas Rules 

of Appellate Procedure, a true and correct copy of this motion has been served as 

follows: 

Douglas R. Drucker via e-Service 

Kirby D. Hopkins 

DRUCKER | HOPKINS LLP 

21 Watery Avenue, Suite 300 

The Woodlands, TX 77380 

Counsel for Appellant 

Eric J. Taube via e-Service 

HOHMANN, TAUBE & SUMMERS LLP 

100 Congress Avenue, 18th Floor 

Austin, Texas 78701 

Counsel for Axiom entities and 

Jeff Compton 

 /s/ Lisa Bowlin Hobbs 

 Lisa Bowlin Hobbs