Court of Appeals Number: 03-15-00008-CV 

PAUL D SIMMONS, Appellant § IN THE 3RD DISTRICT 

VS. COURT OF APPEALS 

TERESA A. SIMMONS, Appellee§ STATE OF TEXAS 

SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

TO THE HONORABLE JUSTICES OF SAID COURT: 

Now comes MELVIN GRAY, attorney for Appellant in the above styled and 

numbered cause, and moves this Court-to grant an extension of time to file appellant's. 

brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good - 

cause shows the following: 

1. This case is on appeal from the 119th Judicial District Court of Tom Green 

County, Texas. 

2. The case was styled TERESA A. SIMMONS v. PAUL D. SIMMONS, 

and bears cause number B130232F. 

3. A judgment was rendered against Appellant on September 15, 2014. 

4. Appellant filed a Request for Findings of Fact and Conclusions of Law on 

October 3, 2014. 

5. Notice of appeal was given on December 12, 2014. 

6. The reporter's record was filed on January 12, 2015, and the clerk's 

record was filed on January 13, 2015. 

7. The appellant's brief is due on April 13, 2015. 

8. One previous extension has been granted. 

9. Attorney for Appellant requests an extension of time of 60 days from the 

present due date to file the brief. 

ACCEPTED

03-15-0008-CV

4900186

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/15/2015 2:05:31 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 4/15/2015 2:05:31 PM JEFFREY D. KYLE Clerk
10. Appellant relies on the following facts as good cause for the requested 

extension: 

• a) Counsel for Appellant, due to the nature of his law practice, 

has had to be out of town and away from his office for the majority of the 

last 60 days'. 

.b) Courisel for Appellant has a very heavy trial court caseload and 

must appear in court on almost a daily basis for a criminal case, civil case or 

family law case.. In order to adequately scrutinize the record and properly 

prepare this brief, the undersigned attorney will need additional time. . 

c) Despite the best efforts of the undersigned attorney, this brief 

cannot be properly prepared in the time allotted. 

11. Counsel has conferred with Kirk Hawkins, attorney for Appellee, and he 

has no objection to this Motion. 

WHEREFORE, PREMISES CONSIDERED, attorney for Appellant prays 

that this Court grant this Second Motion to Extend Time to File Appellant's Brief, and 

for such other and further relief as the Court may deem appropriate. 

Respectfully submitted, 

GRAY & BRIGMAN, PLLC 

206 West College Avenue 

San Angelo, TX 76903 

Tel: (325) 653-4594 

Fax: (325) 657-0039 

By: /s/ Melvin Gray 

MELVIN GRAY 

State Bar No. 08328000 
CERTIFICATE OF SERVICE 

This is to certify that on April 15, 2015, a true and correct copy of the above and 

foregoing document was served on Kirk Hawkins, Attorney for Appellee, via the, 

efiling system. 

/s/ Melvin Gray 

MELVIN GRAY 
STATE OF TEXAS 

COUNTY OF TOM GREEN 

AFFIDAVIT 

• BEFORE ME, the undersigned authority, on this day personally appeared - 

MELVIN GRAY, who after being duly sworn stated: • 

"I am the attorney for the appellant in the above numbered and entitled 

cause. I have read the foregoing Second Motion to Extend Time to File 

Appellant's Brief and swear that all of the allegations of fact contained 

therein are true and correct." 

MELVIN GRAY4-1 

Affiant 

SUBSCRIBED AND SWORN TO BEFORE ME on April 15, 2015, to certify 

which witness my hand and seal of office. 

SALLY GREEN 

Notary Public, State of Texas 

My Commission Expires 

March 14, 2016 

Notary Pub lib, State of Texas