ACCEPTED03-15-00368-CV6448452THIRD COURT OF APPEALSAUSTIN, TEXAS8/11/2015 3:11:38 PMJEFFREY D. KYLECLERKNO.03-15-00368-CVINTHECOURTOFAPPEALSFORTHETHIRDSUPREMEJUDICIALDISTRICTATAUSTINLAURAPRESSLEY,APPELLANTvs.GREGORIO"GREG"CASAR,APPELLEEMOTIONTOEXTENDTIMEFORFILINGAPPELLANT'SBRIEFTOTHEHONORABLECOURTOFAPPEALS:NowcomesLauraPressley,AppellantandpursuanttoTex.R.App.P.10.5,movesthiscourttograntanextensionoftimetofileAppellant'sBrief,andrespectfullystates:1.TheduedateforLauraPressley,Appellant'sBriefiscurrentlyAugust18,2015.ThelastClerk'sRecordandtheReporter'sRecordwasfiledonAugust7,2015.ThetrialcourthasindicateditwillfileanorderonAppellant'srequestforadditionalFindingsofFactandConclusionsofLawinthefuture.ThereforethelastfilingoftheRecordhasnotbeensetasofyet or at a minimum as of th i s 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 p r eparing 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 procrast i nation or for delay.

P RESS L EY M O T ION T O EXTEND TI ME Pag e 24

. Counsel for Laura Pressley has conferred with counsel for
Casar and Casar does not oppose this Motion to Extend Time to September 8 , 2015

. 

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. 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 B r ief

.

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 P r essley also requests any other relief to which she may be
entitled.

PR ESSLEY M OT I O N T O EX TEN D TI ME 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

P age 3

### CERTIFICATE OF CONFERENCE 

### Please be advised that the undersigned has conferred with opposing counsel on August 11 , 2015 regarding th i s Motion, and the Counsel for Gregorio " Greg ll Casar are unopposed to the Court extending the due date for Appellant's brief until September 8,**~**

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P RESSLEY MOT I ON TO EXTEN D 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 pe r sons on this 11 t h 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

PRESS L EY MOT I O N T O E XTEND T I M E

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