Appellant's Second Motion to Extend Time for Filing Appellant's Brief 1 

APPELLATE CASE NO. 06-14-00036-CV 

FRANK KEATHLEY, INDIVIDUALLY IN THE COURT OF APPEALS 

AND DOING BUSINESS AS TOP SHELF 

ANTIQUES, APPELLANT 

V. FOR THE SIXTH DISTRICT 

J.J. INVESTMENT COMPANY, LTD., 

ET AL AND CORBITT BAKER, 

APPELLANTS TEXARKANA, TEXAS 

SECOND MOTION TO EXTEND TIME FOR FILING 

APPELLANT'S BRIEF 

TO THE HONORABLE COURT OF APPEALS: 

 Frank Keathley, individually and doing business as Top Shelf Antiques, appellant, 

moves this Court to grant him an extension of time to file Appellant's Brief and 

respectfully states as follows: 

 1. This appeal is from post-judgment orders entered by the trial court in 

Cause No. 10,072 pending in the 62nd Judicial District Court of Franklin County, Texas, 

signed March 25, 2014. All matters pending in the trial court were stayed by Appellant's 

bankruptcy until this appeal was reinstated by order of this Court dated October 15, 2014 

following Appellant's discharge in bankruptcy. 

 2. The Appellant's Brief for Frank Keathley was originally due January 15, 

2015. The filing date was previously extended to today, February 2, 2015. This motion 

is filed as a request for extension of the filing date for an additional ten days until 

February 12, 2015. If granted, the filing date for Appellant's brief will have been 

extended for a total of 28 days total. 

 3. For good cause shown, Frank Keathley files this motion seeking a ten-day 

extension for filing his Appellant's Brief from February 2, 2015 to February 12, 2015. 

ACCEPTED

06-14-00036-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

2/2/2015 11:42:52 AM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 2/2/2015 11:42:52 AM DEBBIE AUTREY Clerk
Appellant's Second Motion to Extend Time for Filing Appellant's Brief 2 

This motion for extension of time is not filed solely for the purposes of delay of these 

proceedings, but is filed because Appellant's counsel underestimated the time required to 

research and address the points of error relevant to this appeal in making the original 

request for only an eighteen day extension. Appellant's counsel currently has two 

responses to petitions for review that are or will be pending in the Supreme Court and one 

additional case pending for appeal to the Court of Appeals that have also required 

research hours for preparation or in response for filing. On last Thursday, Mr. Keathley 

advised the undersigned counsel of the death of his Mother and requested legal assistance 

with respect to the death, the funeral and the related estate issues, which have resulted in 

a loss of time that would otherwise have been devoted to completing the brief by the 

filing date. 

 4. This is the appellant's second motion for an extension of time to file 

appellant's brief. 

 5. Appellant's counsel personally conferred with counsel for each appellee 

and none oppose this additional ten-day extension. 

 WHEREFORE, Frank Keathley, appellant, moves the Court to consider his 

motion and to grant him an extension of the time for filing his Appellant's Brief from 

February 2, 2015 to no later than February 12, 2015, or such other time as the Court may 

deem appropriate. 
Appellant's Second Motion to Extend Time for Filing Appellant's Brief 3 

Respectfully submitted this 2nd day of February, 2015. 

 /s/ Larry R. Wright 

 Larry R. Wright 

 State Bar No. 22048000 

 P.O. Box 144 

 406 South Main Street 

 Winnsboro, Texas 75494 

 Telephone 903-342-1089 

 Fax 903-342-1088 

 E-mail lawyerwright@msn.com

CERTIFICATE OF CONFERENCE 

 This is to certify that counsel for appellant conferred with counsel of record for 

each appellee and none opposed the motion for an additional extension. 

 Signed this 2nd day of February, 2015. 

 /s/ Larry R. Wright 

 Larry R. Wright 

CERTIFICATE OF SERVICE 

 This is to certify that a copy of the foregoing has been this day served on each 

attorney of record, as follows: 

 Travis P. Clardy 

 Clardy Law Office 

 209 E. Main St. 

 Nacogdoches, TX 75961 

 By fax to 936-564-2507 

 Larry Blount 

 Powers & Blount, LLP 

 PO Box 877 

 Sulphur Springs, TX 75483 

 By fax to 903-885-1199 
Appellant's Second Motion to Extend Time for Filing Appellant's Brief 4 

 Gene Stump 

 PO Box 606 

 Mount Vernon, TX 75456 

 By fax to 903-588-2272 

 Signed this 2nd day of February, 2015. 

 /s/ Larry R. Wright 

 Larry R. Wright