Appellant's motion for extension of time to file reply brief 1 

APPELLATE CASE NO. 06-14-00036-CV 

IN THE COURT OF APPEALS FOR THE SIXTH JUDICIAL DISTRICT 

OF TEXAS AT TEXARKANA, TEXAS 

FRANK KEATHLEY, INDIVIDUALLY, AND DOING BUSINESS AS 

TOP 

SHELF ANTIQUES, APPELLANT 

VS. 

J.J. INVESTMENTS COMPANY, L.L.P., ELLEN JAGGERS, DISTRICT 

CLERK OF 

FRANKLIN COUNTY, TEXAS, FRANKLIN COUNTY CONSTABLE 

RANDY GREEN APPELLEES 

AND 

CORBITT BAKER, APPELLEE AND PARTY AT INTEREST 

Appeal from Cause No. 10,072 in the District Court of Franklin County, 

Texas, 

62nd Judicial District 

The Honorable Will Baird, District Judge 

APPELLANT'S MOTION TO EXTEND TIME 

FOR FILING APPELLANT'S REPLY BRIEF 

ACCEPTED

06-14-00036-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

5/5/2015 4:24:47 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 5/5/2015 4:24:47 PM DEBBIE AUTREY Clerk
Appellant's motion for extension of time to file reply brief 2 

TO THE HONORABLE COURT OF APPEALS: 

 Frank Keathley, individually and doing business as Top Shelf 

Antiques, appellant, files this motion pursuant to Rule 38.6(c) of the Texas 

Rules of Appellate Procedure, as follows: 

 1. The appellee's brief was filed April 15, 2015. Appellant's reply 

brief is due May 5, 2015. 

 2. Appellant requests and extension of twenty (20) days for filing 

his reply brief. The filing date under this extension would be May 25, 2015, 

which is the recognized holiday for Memorial Day this year. Therefore, the 

requested extension due date would be May 25, 2015.

 3. Appellant requests this extension to permit his counsel of 

record to conduct additional research regarding his response to the issues 

raised by appellee's brief. Just prior to receipt of the appellee's brief, 

appellant's counsel had completed a week-long jury trial and has been 

involved in post-verdict motions related to the jury trial which have taken 

time that would otherwise have been available for completion of research 

and preparation of the reply brief. Additionally, appellant's counsel was 

required to accompany his wife to Dallas for outpatient procedures related to 

treatment of recently diagnosed herniated disk issues which have resulted in 

loss of time from his office. 
Appellant's motion for extension of time to file reply brief 3 

 4. This motion is not made solely for the purposes of delay, but is 

made so justice may be done. This is appellant's first motion to extend the 

filing of his reply brief. 

 5. Appellant's counsel personally conferred with counsel for the 

real party at interest and he does not oppose this extension. 

 WHEREFORE, appellant moves the Court to consider this motion and 

to grant him an extension of time to file his reply brief no later than May 26, 

2015, or such other time as the Court may deem appropriate. 

 Respectfully submitted this 5th day of May, 2015. 

 /s/ Larry R. Wright

 Larry R. Wright 

 State Bar No. 22048000 

 P.O. Box 144 

 406 South Main Street 

 Winnsboro, Texas 75494 

 Telephone 903-342-1089 

 Fax 903-342-1088 

 E-mail lawyerwright@msn.com

 Attorney for Appellant 
Appellant's motion for extension of time to file reply brief 4 

CERTIFICATE OF SERVICE 

 This is to certify that a copy of the foregoing has been this day served 

by email transmission to each attorney of record, as follows: 

 Clardy Law Office 

 Jerry W. Baker 

 Attorney for Corbitt Baker 

Real Party at Interest 

Powers & Blount, LLP 

Larry Blount 

Attorney for JJ Investment Co. LTD, et al 

Appellee 

Gene Stump 

Franklin County Attorney 

Attorney for Appellees, Ellen Jaggers and Randy Green 

 /s/ Larry R. Wright

 Larry R. Wright