ACCEPTED

03-14-00529-CV

4312640

THIRD COURT OF APPEALS

AUSTIN, TEXAS

2/27/2015 12:01:31 PM

JEFFREY D. KYLE

CLERK

NO. 03-14-00529-CV 

3Jn tbe \!rbirb (!Court of ~ppeals 

JEROME J. ISAAC AND MICHELLE P. ISAAC, 

Appellants, 

v. 

VENDOR RESOURCE MANAGEMENT, INC.; MORTGAGE ELECTRONIC 

REGISTRATION SYSTEMS, INC. AND CITIMORTGAGE, INC., 

On Appeal from Cause No. 13-04720-C26 

261

h District Court, Williamson County, Texas 

Han. Billy Ray Stubblefield, Judge Presiding 

UNOPPOSED MOTION FOR EXTENSION OF TIME 

Appellees. 

TO FILE BRIEF OF APPELLEE VENDOR RESOURCE MANAGEMENT 

TO THE HONORABLE THIRD COURT OF APPEALS: 

Comes now, VENDOR RESOURCE MANAGEMENT, INC. ("Appellee") and respectfully 

move the Court to extend the time to file APPELLEE'S BRIEF by 30 days to April 3, 2015 and 

for said motion would show the Court as follows: 

A. Background 

1. The notice of appeal for this cause was filed on August 26, 2014 and the Clerk's 

Record was filed on November 6, 2014. 

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 2/27/2015 12:01:31 PM JEFFREY D. KYLE Clerk
2. The Reporter's Record was filed on November 17, 2014. Appellant's brief was filed 

on February 2, 2015, after a notice of late brief and the granting of an unopposed extension. 

3. Appellee's brief is currently due on March 4, 2015. Appellee requests an additional 30 

days to file Appellee's brief, extending the due date to April 3, 2015. 

B. Argument & Authorities 

4. No rule limits the time to file this motion to extend. The Court may grant an extension 

of time under Texas Rule of Appellate Procedure 38.6(d). 

5. No previous extension of time to file Appellee's brief has been granted nor sought in 

this matter. 

6. Appellee asks that the Court grant an extension of time to file Appellee's brief from 

such due date, or such other date as the court calculates, until April 3, 2015. Appellee's counsel 

has been unable to devote an appropriate effort to preparation of the brief due to professional and 

personal demands on Appellee's Counsel's time. During the briefing period, Appellee's counsel 

had due two motions for summary judgment and two answers for suits filed in federal court in 

addition to his usual case load and court appearances. In addition, Appellee's counsel had three 

significant family obligations during the briefing period that have made it difficult to work 

during the evenings and on weekends. 

D. Prayer 

7. For these reasons, Appellee asks the Court to grant an extension of time to file its brief 

until April3, 2015 and grant Appellee such other and further reliefto which it may be entitled or 

is in the interest of justice. 
Respectfully Submitted, 

JACK O'BOYLE & ASSOCIATES 

Attorney for Appellee 

Is/Chris Ferguson 

o Jack O'Boyle 

SBN 15165300 

o Travis Gray 

SBN 24044965 

XXChris Ferguson 

SBN 24069714 

P.O. Box 815369 

Dallas, Texas 75381 

Phone: 972.247.0653 

Fax: 972.247.0642 

chris@jackoboyle.com 

Certificate Regarding Conference 

I conferred with Appellant's Attorney, Michael Brinkley, by email on February 26, 2015 

and Mr. Brinkley stated that he is not opposed to this motion. In addition, I also contacted 

counsel for the other Appellee's, John Ellis, and he too is unopposed to this motion. 

Date: February 27, 2015 

Is/Chris Ferguson 

Chris Ferguson 

Certificate of Service 

I certifY that on February 27, 2015 a true and correct copy of the foregoing was served 

via EFILETx.Gov e-service upon the following: 

Michael Brinkley 

BRINKLEY LAW, PLLC 

TBN: 03004300 

m@michaelbrinkley .com 

P.O. BOX 820711 

FORTH WORTH, TEXAS 76182 

P: 817.284.3535 II F: 888.388.6031 

Counsel for Michelle P. and Jerome 

J. Isaac 

Susan A. Kidwell and John W. Ellis 

Locke Lord L.L.P. 

jellis@lockelord.com 

TBN: 24032626 TBN: 24078473 

600 Congress A venue, Suite 2200 

Austin, Texas 78701 

P: 512.305-470011F:512.305.4800 

Counsel for Citimortgage, Inc., and 

Mortgage Electronic Registration 

Systems, Inc. 

Is/Chris Ferguson 

Chris Ferguson