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Case No. 12-15-00004-CV

 IN THE 

TWELFTH COURT OF APPEALS 

TYLER, TEXAS 

__________________________________________________________________ 

RON SEALE, INDIVIDUALLY AND AS THE REPRESENTATIVE OF THE 

ESTATE OF CLARA LAVINIA SEALE, 

Appellant, 

v.

HORACE TRUETT SEALE AND WIFE, NAN SEALE, 

 Appellees.

__________________________________________________________________ 

APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE 

APPELLATE BRIEF (RULE 38.6(d)) 

__________________________________________________________________ 

TO THE HONORABLE COURT OF APPEALS: 

 Comes now Appellant, Ron Seale, Individually and as the Representative of 

the Estate of Clara Lavinia Seale, Deceased, and presents this his motion for 

extension of time to file appellant’s brief and in support thereof would respectfully 

show unto the Court as follows: 

I.

That counsel for the Appellant is scheduled for an annual vacation from 

March 19, 2015 to March 27, 2015, outside the state. 

ACCEPTED

12-15-00004-CV

TWELFTH COURT OF APPEALS

TYLER, TEXAS

3/20/2015 12:42:54 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 3/20/2015 12:42:54 PM CATHY S. LUSK Clerk
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II.

That Appellant’s counsel is set for jury trial from March 31, 2015 to April 3, 

2015. 

III.

That during the past thirty (30) days, counsel for the Appellant has had the 

following scheduled:

Federal Administrative Hearings – 12

Depositions - 6

Mediations - 1

Court Settings - 9

As a result, counsel for the Appellant has been unable to prepare the 

Appellant’s brief.

IV.

No previous extensions have been granted by the Court and none have been 

requested.

V.

The extension of time requested will not prejudice or inconvenience 

Appellees in any manner, nor will the time for submission of this case be extended 

by granting an extension of time in which to file Appellant’s brief. 
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VI.

Richard L. Ray, counsel for Appellant has attempted to conference with 

John F. (Jack) Walker, III, Martin Walker, P.C., counsel for Appellees, on March 

20, 2015, concerning the requested extension and was told by Mr. Walker’s staff 

that he informed by email that he does not opposes this motion.

PRAYER FOR RELIEF

Therefore, Appellant respectfully requests that the Court issue an order 

extending the time for filing the Appellant’s brief in the above case to May 1, 

2015.

Respectfully submitted,

RAY & THATCHER, 

ATTORNEYS AT LAW, PC

/s/ Richard L. Ray

RICHARD L. RAY

State Bar No. 16606300

VICTORIA RAY THATCHER

State Bar No. 24054462

300 South Trade Days Blvd.

Canton, Texas 75103

903-567-2051

903-567-6998 (fax)

rlray@rayandthatcher.com

ATTORNEYS FOR APPELLANT
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CERTIFICATE OF CONFERENCE

I, Richard L. Ray, do hereby certify that I attempted to conference with John 

F. (Jack) Walker, III on March 20, 2015, for purposes of this Certificate of 

Conference, and was told by Mr. Walker’s staff that he informed by email he is not

opposed to Appellant’s Motion for Extension of Time to File Brief (Rule 38.6(d)).

/s/ Richard L. Ray

RICHARD L. RAY
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CERTIFICATION

I certify that a copy of this motion has been provided to all the following 

counsel of record this the 20th day of March, 2015: 

John F. (Jack) Walker, III

Martin Walker, P.C.

The Arcadia Theater

121 N. Spring Avenue

Tyler, Texas 75702

(903) 595-0796 – fax.

/s/ Richard L. Ray

RICHARD L. RAY