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 MICHELLEP. ISAAC, 

### Appellants, 

### v. VENDORRESOURCE MANAGEMENT,INC.; MORTGAGEELECTRONIC REGISTRATION SYSTEMS,INC. AND CITIMORTGAGE,INC.,

On

### Appeal from Cause No. 13-04720-C26 261 h

### District Court, Williamson County, Texas Han. BillyRayStubblefield, Judge Presiding

UNOPPOSEDMOTIONFOREXTENSION OFTIME 

### Appellees.

TOFILEBRIEF OFAPPELLEE VENDORRESOURCEMANAGEMENT

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.

### 2. The Reporter's Record was filed on November 17, 2014. Appellant's briefwas filed
on February 2, 2015, after a notice oflate briefand the granting ofan unopposed extension.
3. Appellee's briefis currently due on March 4, 2015. Appellee requests an additional 30 days to file Appellee's brief, extendingthe 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 oftime under Texas Rule ofAppellate Procedure 38.6(d).
5. No previous extension oftime to file Appellee's briefhas been granted nor sought in this matter. 6. Appellee asks that the Court grant an extension oftime to file Appellee's brieffrom 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 ofthe briefdue to professional and personal demands on Appellee's Counsel's time. During the briefing period, Appellee's counsel had due two motions for summaryjudgment 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 oftime 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, JACKO'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 otherAppellee's, John Ellis, and he too is unopposedto this motion. Date: February 27, 2015 Is/Chris Ferguson Chris Ferguson

Certificate ofService IcertifY that on February 27, 2015 atrue and correct copy ofthe foregoing was served viaEFILETx.Gov e-service uponthe following:
Michael Brinkley BRINKLEY LAW, PLLC TBN: 03004300 m@michaelbrinkley.com P.O. BOX 820711 FORTH WORTH, TEXAS 76182 P: 817.284.3535 

### IIF: 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 Avenue, 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