No. 06-14-00099-CV

—————————

IN THE COURT OF APPEALS

FOR THE SIXTH DISTRICT OF TEXAS AT TEXARKANA

—————————————————————————————————

RICHARD PARKER

Appellant

v.

JOANN PARKER NEAL

Appellee

—————————————————————————————————

On Appeal from the 276th District Court of Camp County

Robert Rolston, Judge Presiding

—————————————————————————————————

UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF

—————————————————————————————————

Appellee JoAnn Parker Neal moves for an unopposed extension of time to file

her Appellee’s brief in this proceeding and states the following in support:

I.

Appellee’s brief is due to be filed on April 24, 2015. Appellee respectfully

requests a thirty-day extension of time, until May 24, 2015, to file her brief. Appellee

is not filing this motion for the purpose of delay, but in the interest of justice.

UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF Page 1

ACCEPTED

06-14-00099-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

4/13/2015 10:55:34 AM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 4/13/2015 10:55:34 AM DEBBIE AUTREY Clerk
II.

AppellantRichard Parkerrequested and was granted two unopposed extensions

of time to file his Appellant’s brief.

III.

Appellee has been represented in this appeal by her trial counsel, Lance

Hinson. Appellee has now determined that it would be in her best interest to be

represented on appeal by an attorney who focuses his practice on appellate law. As

such, Appellee hired Chad Ruback to be her lead appellate counsel. Ruback is filing

his notice of appearance of counsel and designation of lead counsel

contemporaneously with this motion.

Ruback is busy preparing the following other appellate briefs:

(1) an appellant’s brief in LBSP, Inc. Forest Dale, Inc., 05-14-01295-CV in

the Dallas Court of Appeals, due on April 15, 2015; and

(2) an appellant’s reply brief in Meyer v. Meyer, 05-14-00655-CV in the

Dallas Court of Appeals, due on May 15, 2015.

Consequently, Ruback will be unable to complete Appellee’s brief in this case

by the April 24, 2015 deadline.

UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF Page 2
IV.

WHEREFORE, PREMISES CONSIDERED, Appellee JoAnn Parker Neal

prays that this Court enter an order granting her Unopposed Motion for Extension of

Time to File Appellee’s Brief and specifying that Appellee’s brief be filed on or

before May 24, 2015.

Respectfully submitted,

/s/ Chad M. Ruback

Chad M. Ruback

State Bar No. 90001244

The Ruback Law Firm

8117 Preston Road

Suite 300

Dallas, Texas 75225

(214) 522-4243

(214) 522-2191 facsimile

chad@appeal.pro

CERTIFICATE OF CONFERENCE

On April 13, 2015, I conferred with Tom S. McCorkle, counsel for Appellant

Richard Parker, and he is unopposed to the relief sought in this motion.

/s/ Chad M. Ruback

Chad M. Ruback

UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF Page 3
CERTIFICATE OF SERVICE

On April 13, 2015, I served a copy of this document to the following counsel

for Appellant Richard Parker:

Tom S. McCorkle

403 W. Tyler Street

Gilmer, Texas 75644

/s/ Chad M. Ruback

Chad M. Ruback

UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF Page 4