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No. 14-14-01007-CV 

IN THE FOURTEENTH COURT OF APPEALS OF TEXAS 

THOMAS BEETS AND LESLIE BEETS 

APPELLANTS, 

v. 

NATIONAL COLLEGIATE STUDENT LOAN TRUST 2005-2, 

A DELAWARE STATUTORY TRUST 

APPELLEE. 

On Appeal from National Collegiate Student Loan Trust 2005-2, A Delaware 

Statutozy Trust v. Thomas Beets and Leslie Beets, No. CV28146 (344th Judicial 

District Court, Chambers County, Tex. Jan 15, 2014). 

Hon. Randy McDonald, Presiding 

APPELLEE'S UNOPPOSED MOTION TO EXTEND TIME TO FILE 

APPELLEE'S RESPONSE BRIEF ON THE MERITS 

MICHAEL J. SCOTT 

State Bar No. 24000876 

TERI STEW ART MACE 

State Bar No. 12759480 

JUDITH M ORGAN 

State Bar No. 00789500 

courts@scott-pc.com 

Scott, Parnell, and Associates 

P.O. Box 115220 

Carrollton, Texas 75006 

Tel: 214.234.8456 

Fax: 214.234.8454 

ATTORNEYS FOR PLAINTIFF 

ACCEPTED

14-14-01007CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

6/12/2015 3:16:35 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 6/12/2015 3:16:35 PM CHRISTOPHER A. PRINE Clerk
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APPELLEE'S UNOPPOSED MOTION TO EXTEND TIME TO FILE 

APPELLEE'S RESPONSE BRIEF ON THE MERITS 

Appellee respectfully requests that the Court grant it 30 days to file its Response Brief on 

the Merits in the instant appeal. 

I 

BACKGROUND 

1. This Motion is filed pursuant to, and in compliance with Texas Rules of Appellate 

Procedure 10.5 and 38.6( d). 

2. On September 26'\ 2014, the 344'h Judicial District Court of Chambers County, Texas 

signed a Final Summary Judgment in Case No. CV28146 , National Collegiate Student Loan 

Trust 2005-2, A Delaware Statutory Trust v. Thomas Beets and Leslie Beets. ("Final Surmnary 

Judgment", attached as Exhibit A). 

3. On December 22, 2014, Appellants filed its Notice of Appeal ("Notice of Appeal", 

attached as Exhibit B). 

4. On March 3, 2015, Appellants filed their first Motion for Extension of Time to File Brief, 

which Motion for Extension was granted. 

5. On April 1, 2015, Appellants filed their second Motion for Extension of Time to File 

Brief, which second Motion for Extension was granted. 

6. On May 6, 2015, Appellants filed their third Motion for Extension of Time to File Brief, 

which third Motion for Extension was granted. 

7. On May 21,2015, Appellants filed Appellants' Brief. 

8. The Court has not granted Appellee any prior extensions of time in the instant appeal. 

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11. 

APPELLEE'S MOTION FOR EXTENSION OF TIME 

9. Appellee respectfully requests an additional 30 days to submit its responsive brief to the 

Court. Appellant was representing in the trial proceeding by Regent and Associates. Mr. R. 

Chan Tysor of Scott Parnell & Associates, P.C. (the "Firm") appeared on behalf of Appellee only 

at the hearing on the Appellant's Motion for New Trial. Mr. Tysor is not the attorney handling 

the appeal for Appellee. The Firm attorney responsible for this appeal left the Firm yesterday, 

June 11, 2015, without preparing the responsive brief. Due to circumstances at the Firm beyond 

the control of Appellee, Appellee needs additional time to adequately prepare its brief. 

Ill. 

CONCLUSION 

I 0. Appellee respectfully requests an additional 30 days to submit its responsive brief to the 

Court due to the departure ofthe attorney primarily responsible for preparing Appellee's Brief. 

(401723) 

IV. 

PRAYER 

WHEREFORE, Appellee prays that the Court: 

a. Issue its Order Granting Appellee at least 30 days for Appellee to file its Brief in 

Response. 

Carrollton, Texas 75006 

Tel: 214.234.8456 

Fax: 214.234.8454 

ATTORNEYS FOR PLAINTIFF 

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CERTIFICATE OF SERVICE 

The undersigned certifies that a true and correct copy of the foregoing Motions was been 

served via United States Postal Service First Class Mail, this ___ day of June, 2015 on the 

following: 

Robert B. Hinsley 

The Hinsley Law Firm 

6001 Savoy Drive, Suite 115 

Houston, Texas 77036 

Telephone: 713-465-9000 

Facsimile: 713-465-9997 

bjennings@consumersdefense.com 

ATTORNEY FOR APPELLANTS 

~ Teri Stewart Mace 

Judith Morgan 

CERTIFICATE OF CONFERENCE 

I hereby certifY that on June 12, 2015, I have conferred with counsel for Appellants, who 

stated that this Motion is unopposed. Tex. R. App. P. Ann. lO.l(a)(5) (West 2014). 

(401723) 4 

eri Stewart Mace 

Judith Morgan