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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

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 7/29/2015 2:54:52 PM JEFFREY D. KYLE Clerk
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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 319th 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.
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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, APPELLANT
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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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