### No. 14-14-01007-CV

IN THE FOURTEENTH COURT OFAPPEALS OF TEXAS


### THOMAS BEETS ANDLESLIEBEETS APPELLANTS, 

## v. NATIONAL COLLEGIATE STUDENTLOAN TRUST 2005-2, A DELAWARESTATUTORYTRUST APPELLEE.


### OnAppeal from National Collegiate StudentLoan Trust 2005-2, 

### A Delaware Statutozy Trust v. Thomas Beets andLeslieBeets, 

### 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 BarNo. 24000876 TERI STEW ARTMACE State BarNo. 12759480 JUDITH MORGAN State BarNo. 00789500 courts@scott-pc.com Scott, Parnell, andAssociates P.O. Box 115220 Carrollton, Texas 75006 Tel: 214.234.8456 Fax: 214.234.8454 ATTORNEYS FORPLAINTIFF ACCEPTED 14-14-01007CV FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS 6/12/2015 3:16:35 PM CHRISTOPHER PRINE

CLERK

### 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 Briefon 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 ofChambers 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 andLeslie 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 ofTime 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 Motionfor Extension was granted. 6. On May 6, 2015, Appellants filed their third Motion for Extension ofTime to File Brief, which third Motion for Extension was granted. 7. On May 21,2015, Appellants filed Appellants' Brief. 8. The Courthas not granted Appellee any prior extensions oftime in the instant appeal.

(401723) 2

### 11. APPELLEE'S MOTIONFOREXTENSION OF TIME 9. Appellee respectfully requests an additional 30 days to submit its responsive briefto the Court. Appellant was representing in the trial proceeding by Regent and Associates. Mr. R. Chan Tysor ofScottParnell & Associates, P.C. (the "Firm") appeared onbehalfofAppellee 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 ofAppellee, Appellee needs additional time to adequately prepare its brief. 

### Ill. CONCLUSION I0. Appellee respectfully requests an additional 30 days to submit its responsive briefto the Court due to the departure ofthe attorney primarilyresponsible for preparing Appellee's Brief.

(401723) IV. PRAYER WHEREFORE, Appellee prays thatthe Court:
a. Issue its Order Granting Appellee at least 30 days for Appellee to file its Briefin Response.

Carrollton, Texas 75006 Tel: 214.234.8456 Fax: 214.234.8454 ATTORNEYS FORPLAINTIFF

3CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy ofthe foregoing Motions was been served via United States Postal Service First Class Mail, this
___day ofJune, 2015 on the following: Robert B. Hinsley The HinsleyLawFirm 6001 Savoy Drive, Suite 115 Houston, Texas 77036 Telephone: 713-465-9000 Facsimile: 713-465-9997 bjennings@consumersdefense.com ATTORNEYFORAPPELLANTS

# ~ Teri Stewart Mace Judith Morgan

CERTIFICATE OF CONFERENCE Ihereby certifY thatonJune 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 JudithMorgan