1 No. 03-15-00083-CV

___________________________________________________________

In the Third District Court of Appeals

Houston, Texas

___________________________________________________________

CRAIG A. WASHINGTON, Appellant,

vs. COMMISSION FOR LAWYER DISCIPLINE,

Appellee.

___________________________________________________________ UNOPPOSED SECOND MOTION OF CRAIG A. WASHINGTON TO

EXTEND DEADLINE FOR PRINCIPAL BRIEF

___________________________________________________________ Appellant Craig A. Washington asks that this Court extend for fourteen (14) days the deadline for the filing of his principal brief as the appellant in the above-captioned case, making the new briefing deadline August 17, 2015. In support Mr. Washington states:
1. This is an appeal from a final judgment signed January 8, 2015. The completed clerk’s record was filed June 2, 2015, and the reporter’s record was filed May 15, 2015. Therefore, the principal brief of the appellant is was initially due July 2, 2015. TEX
. R. APP
. P. 38.6(a). This court can extend that deadline, and ACCEPTED 03-15-00083-CV 6276625 THIRD COURT OF APPEALS

AUSTIN, TEXAS 7/29/2015 2:54:52 PM JEFFREY D. KYLE

CLERK2

has extended it to August 3, 2015. Id. 38.6(d). This is the appellants’ second request to extend the deadline, and it is unopposed.
2. Counsel for Mr. Washington, John MacVane, is principally responsible for drafting the brief and was trial counsel in urgent temporary restraining order and temporary injunction proceedings in Berry GP, Inc. v. BTB Refining, LLC

, Cause No. 2015DCV-2205, currently pending in the 319 th Judicial District Court, Nueces County, in Corpus Christi. This case required Mr. MacVane to travel to Corpus Christi last week in preparation for a temporary injunction hearing held July 23, 2015. Mr. MacVane spent much of the last month preparing witnesses and materials for the temporary injunction hearing, which was not anticipated when Mr. Washington filed his initial request for an
extension. 3. In order to adequately focus on the briefing in this case, Mr. Washington requests a 14-day extension of the deadline for his appellant’s brief. A 14-day extension of the briefing deadline would make appellants’ brief due on Monday, August 17, 2015.3 Request for Relief For the above reasons, Craig A. Washington asks this Court to extend for 14 days the deadline for the filing of his principal brief in this appeal, making the new deadline August 17, 2015.
Respectfully submitted, /s/ John MacVane Michael A. Stafford Texas Bar No. 18996970 Katharine David Texas Bar No. 24045749 John MacVane Texas Bar No. 24085444 Gardere Wynne Sewell LLP 1000 Louisiana, Suite 2000 Houston, Texas 77002-5007 Tel: 713.276.5500 Fax: 713.276.5555 mstafford@gardere.com kdavid@gardere.com jmacvane@gardere.com
ATTORNEYS FOR CRAIG A. WASHINGTON, APPELLANT4 CERTIFICATE OF SERVICE I certify that a copy of this document was served on July 29, 2015, by delivery to the following counsel via the Electronic Filing Manager: Cynthia Canfield Hamilton Office of the Chief Disciplinary Counsel State Bar of Texas Post Office Box 12487 Austin, Texas 78711 chamilton@texasbar.com
/s/ John MacVane John MacVane



### Certificate of Conference The parties’ counsel have conferred regarding the relief requested in this motion. Counsel for the appellee—Commission for Lawyer Discipline— indicated that it will not oppose this request for relief.
/s/ John MacVane John MacVane

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