LAURA PRESSLEY, 

APPELLANT 

vs. 

GREGORIO "GREG" CASAR, 

APPELLEE 

MOTION TO EXTEND TIME FOR FILING APPELLANT'S BRIEF 

TO THE HONORABLE COURT OF APPEALS: 

Now comes Laura Pressley, Appellant and pursuant to Tex.R.App.P. 

1 0.5, moves this court to grant an extension of time to file Appellant's Brief, 

and respectfully states: 

1. The due date for Laura Pressley, Appellant's Brief is currently 

August 18, 2015. The last Clerk's Record and the Reporter's Record was 

filed on August 7, 2015. The trial court has indicated it will file an order on 

Appellant's request for additional Findings of Fact and Conclusions of Law 

in the future. Therefore the last filing of the Record has not been set as of 
yet or at a minimum as of this date was August 7, 2015. Tex. R App. P. 

38.6(a). 

2. Laura Pressley seeks an extension of time to file Appellant's 

brief for 20 days from the current stated due date of August 18, 2015 or 

until September 8, 2014. The extension is needed because the record in 

this case is voluminous and rather disorganized making preparing the brief 

and appendix very time consuming, Appellant's attorney will be out of the 

office from August 22 until September 1, 2015 on a combination 

family/business trip and will be unable to work on the brief during that time, 

and Appellant's attorney has depositions and other professional 

commitments that will prevent him from working on the brief exclusively 

between the date hereto and August 18, 2015. As a result of the series of 

judgments and other post judgment activities of the trial court , the length 

and status of the record and the series of supplements and Appellant's 

attorney's schedule , the brief cannot be properly and efficiently prepared 

and filed before September 8, 2015. 

3. Therefore, this Motion is in the interest of justice and orderly 

presentation of the issues that need to be resolved in this appeal and not 

for by reason of any procrastination or for delay. 

PRESSLEY MOTION TO EXTEND TIME Page 2 
4. Counsel for Laura Pressley has conferred with counsel for 

Casar and Casar does not oppose this Motion to Extend Time to 

September 8, 2015. 

5. Appellant attempted to file a previous Motion but was told it was 

premature and it was not accepted for filing. Consequently this is the first 

extension of time Laura Pressley has presented to this honorable Court for 

the filing of the Appellant's Brief. 

PRAYER 

For these reasons, Laura Pressley requests that this court enter an 

order extending the time for filing Appellant's Brief until September 8, 2015 

Laura Pressley also requests any other relief to which she may be 

entitled. 

PRESSLEY MOTION TO EXTEND TIME 

Respectfully Submitted, 

Mark Co en 

SBN: 04508400 

805 West 1oth Street, Suite 1 00 

Austin, Texas 78701 

(512) 474-4424 Telephone 

(512) 472-5444 Facsimile 

mark@cohenlegalservices.com 

ATTORNEY FOR APPELLANT 

Page 3 
CERTIFICATE OF CONFERENCE 

Please be advised that the undersigned has conferred with opposing 

counsel on August 11 , 2015 regarding this Motion, and the Counsel for 

Gregorio "Gregll Casar are unopposed to the Court extending the due date 

for Appellant's brief until September 8, ~ 

-M-a-~-C-o he--7---------------

PRESSLEY MOTION TO EXTEND TIME Page 4 
CERTIFICATE OF SERVICE 

This is to certify that a true and correct copy of the above and 

foregoing has been served by efile and/or facsimile to the following persons 

on this 11th day of August, 2015. 

Kurt Kuhn 

State Bar No. 24002433 

KUHN HOBBS PLLC 

3307 Northland Drive,# 310 

Austin, Texas 78731 

(512) 476-6000 Telephone 

(512) 476-6002 Facsimile 

Kurt@KuhnHobbs.com 

Charles 'Chuck' Herring Jr. 

State Bar No. 095341 00 

Herring & Irwin, L.L.P. 

1411 West Avenue, Ste 100 

Austin, TX 78701 

(512) 320-0665 Telephone 

(512) 519-7580 Facsimile 

cherring@herring-irwin. com 

ATTORNEYS FOR APPELLEE 

GREGORIO "GREG" CASAR 

David A. Rogers 

State Bar No. 24014089 

1201 Spyglass Drive, Suite #1 00 

Austin, Texas 78746 

(512) 923-1836 Telephone 

(512) 201-4082 Facsimile 

Firm@DARogerslaw.com 

To be appearing prose later 

PRESSLEY MOTION TO EXTEND TIME 

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