NO. 03-16-00581-CV 

IN THE THIRD COURT OF APPEALS

AUSTIN, TEXAS

BROOKE BRUCE, 

Appellant, 

v. 

CARTER BRUCE, 

Appellee. 

On Appeal from the 345th Judicial District Court of Travis County, Texas 

Trial Court Cause No. D-1-FM-06-002028 

FIRST MOTION FOR 

EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

Kacy L. Dudley 

State Bar No. 24069638 

DUDLEY LAW, PLLC 

1717 West Sixth Street, Suite 315 

Austin, Texas 78703 

(512) 617-3975 (telephone) 

(512) 479-7910 (facsimile) 

kdudley@dudley-law.com 

COUNSEL FOR APPELLANT

 

ACCEPTED

03-16-00581-CV

13853976

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/17/2016 2:22:14 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/17/2016 2:22:14 PM JEFFREY D. KYLE Clerk
APPELLANT’S FIRST MOTION FOR 

EXTENSION OF TIME TO FILE BRIEF PAGE 2 OF 4 

TO THE HONORABLE THIRD COURT OF APPEALS IN AUSTIN, TEXAS: 

 Appellant Brooke Bruce (“Appellant”) files this First Motion for Extension of 

Time to File Petition for Review under TEX. R. APP. P. 10.1, 10.5(b), and 38.6(d), 

and in support thereof would respectfully show the following: 

1. Appellant’s Brief is currently due on Monday, November 21, 2016. 

Appellant requests an extension of time of thirty days, to December 21, 2016. This 

is Appellant’s first request for an extension of time in this case. 

2. The extension will permit counsel to fully analyze the record and 

relevant law and thus prepare thorough briefing to aid the Court in its consideration 

of this appeal: to conduct additional legal research as appropriate, and to include 

such additional factual and legal support in the briefing to present to this Court. 

3. In addition to preparing the briefs in this case, counsel for Appellant, 

who is the sole attorney in her law practice, has recently devoted time to discovery 

responses in two different matters due November 11 and November 15, various 

hearings, mediations and attending a seminar in addition to the other legal and 

administrative responsibilities of managing a law practice. 

4. The undersigned has attempted to confer with opposing counsel, who 

has not yet responded. This extension is not sought for delay, and no party will be 

prejudiced if it is granted. 
APPELLANT’S FIRST MOTION FOR 

EXTENSION OF TIME TO FILE BRIEF PAGE 3 OF 4 

For the foregoing reasons, Appellant respectfully requests that the Court grant 

this thirty-day extension to file her brief, creating a new deadline of December 21, 

2016. 

Respectfully submitted, 

DUDLEY LAW, PLLC 

1717 West Sixth Street, Suite 315 

Austin, Texas 78703 

(512) 617-3975 Telephone 

(512) 479-7910 Facsimile 

By: /s/ Kacy L. Dudley 

Kacy L. Dudley 

State Bar No. 24069638 

kdudley@dudley-law.com 

CERTIFICATE OF CONFERENCE 

 As required by TEX.R. APP. P. 10.1(a)(5), I certify that via email on November

17, 2016, I attempted to confer with Ms. Cecilia Wood, counsel for CARTER 

BRUCE, who has not yet indicated whether this motion is opposed. 

/s/ Kacy L. Dudley 

Kacy L. Dudley 

CERTIFICATE OF SERVICE 
APPELLANT’S FIRST MOTION FOR 

EXTENSION OF TIME TO FILE BRIEF PAGE 4 OF 4 

 I hereby certify that a true and correct copy of the foregoing document was 

served in accordance with the Texas Rules of Appellate Procedure on Thursday, 

November 17, 2016 as follows: 

Cecilia M. Wood 

919 Congress Ave., Ste. 830 

Austin, Texas 78701 

Via Email: Cecilia@ceciliawood.com 

Attorney for Carter Bruce 

/s/ Kacy L. Dudley 

Kacy L. Dudley