IN THE COURT OF APPEALS 

FOR THE TWELFTH APPELLATE DISTRICT OF TEXAS 

TYLER, TEXAS 

IN THE MATTER OF THE ESTATE 

OFRUBYRENEEBYROM 

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§ CAUSE NUMBER 12-15-00033-CV 

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SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF 

NOW COMES JILL CAMPBELL PENN in the above styled and numbered cause, and 

files this motion for the Court to extend the time for filing of the Appellee's Brief pursuant to the 

Texas Rules of Appellate Procedure and for good cause shows the following: 

I. 

The Appellee's Brief is currently due in the Court of Appeals on July 17, 201 5. Appellant's 

Briefwas filed on May 18, 201 5. 

II. 

Appellee seeks an extension oftime until July 31, 2015, to file Appellee's Brief. There 

has been one previous extension of time granted with regard to the filing of Appellee's Brief. 

III. 

It has not been possible for Counsel to complete the brief due to: 

-preparing for an open plea hearing on June 25, 2015 in Cause Nos. F-15-140-211, F15-141-

211, and F-15-930-211 ; 

Page 1 of 4 

ACCEPTED

12-15-00033-CV

TWELFTH COURT OF APPEALS

TYLER, TEXAS

7/15/2015 12:10:06 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 7/15/2015 12:10:06 PM CATHY S. LUSK Clerk
- in Cause No. 05-15-00799-CV, filing a notice of appeal on June 30, 201 5, and other appellate 

motions on July 9, 2015; 

- preparing for a July 1, 2015 hearing in Cause Nos. 15-04677-431 and 2011-71127-431; 

-preparing for a July 7, 2015 hearing in Cause No. 15-04168-393; 

- assisting with an out-of-state hearing held July 7, 2015, involving significant family '\iolence 

issues in a case out of the 393ro Judicial District Court; 

-in Cause No. 2012-70317-431, filing an emergency motion on July 1, 2015, seeking emergency 

relief on July 2, 2015, and preparing for a July 15, 2015 hearing; 

- and being out of state for a family wedding July 9-14, 2015. 

Counsel has worked on Appellee's Brief throughout this time but seeks additional time to 

complete said brief. 

This motion is made in good faith and is not a dilatory tactic. 

WHEREFORE, PREMISES CONSIDERED, Jill Campbell Penn prays that the Court 

grant the Second Motion for Extension of Time to File Appellee's Brief, and that the deadline for 

filing the briefbe extended until July 31, 2015. 

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I verify that the facts stated above are true. 

Respectfully submitted, 

Joseph F. Zellmer 

State Bar Number 22258515 

620 West Hickory Street 

Denton, Texas 76201 

Telephone: 940/383-2674 

Fax: 940/382-7174 

By: __ +--r-----,,;£---------

Josep er 

Lead sel for Jill Campbell Penn 

SUBSCRIBED AND SWORN TO BEFORE ME, on this the \ s-day of X~, 

2015, to certify which witness my hand and seal of office. 

4{~~~~ SUNNIE PALMER (l~~!z:A· :ti~ Notary Public. state onexos 

\~· .... W My Commission Expires 

"•,,'l,~,'..'(#' AJ?!II 26, 2016 ~J • .lc 

Notary Public, State of Texas 

CERTIFICATE OF CONFERENCE 

This is to certify that my staff spoke with Appellant's Counsel Joe Shumate on July 15, 

2015, and he is unopposed to this motion. 

Joseph F. 

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CERTIFICATE OF SERVICE 

I hereby certify that on this the 15th day of July, 2015, a true and correct copy of the above 

and foregoing First Motion for Extension of Time to File Appellee's Brief was served on Joe 

Shumate, by eservice. 

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