1 

## No. 03-15-00280-CV 

# In the Third Court of Appeals **Austin, Texas**

_________________________ ______________________ Michael J. DeLitta, Appellant

v. Nancy Schaefer Appellee

_________________________ ______________________
U NOPPOSED M OTION FOR E XTENSION OF T IME

____________________________ _________________________

T O T HE H ONORABLE T HIRD C OURT OF A PPEALS : Pursuant to Texas Rules of Appellate Procedure 38.6(d) and 10.5(b), Appellee
Nancy Schaefer files this motion for extensi on 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

CLERK2 II.
Tragedy has struck the T AYLOR , D UNHAM AND R ODRIGUEZ family, as David
Dunham’s young son died unexpectedly. While Mr. Dunham is not counsel of record
in this appeal, the sad situation has create d uncertainty in the small firm’s docket.

Additional time would allow th e partners to support each ot her 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 th at he does not oppose the relief sought

in this motion.

P RAYER 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.3 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 T AYLOR D UNHAM & R ODRIGUEZ 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 K UHN H OBBS 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 H OWARD F. C ARTER , J R ., P.C. 5600 Tennyson Parkway, Suite 160 Plano, Texas 75024 (972) 455-2001 (972) 455-2015 (fax)

C ERTIFICATE OF C ONFERENCE Pursuant to Texas Rule of Appellate Pr ocedure 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 Hobbs4 C ERTIFICATE OF S ERVICE 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 D RUCKER | H OPKINS LLP 21 Watery Avenue, Suite 300 The Woodlands, TX 77380 Counsel for Appellant
Eric J. Taube via e-Service H OHMANN , T AUBE & S UMMERS LLP 100 Congress Avenue, 18th Floor Austin, Texas 78701 Counsel for Axiom entities and Jeff Compton

/s/ Lisa Bowlin Hobbs Lisa Bowlin Hobbs