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

CLERKAppellant's Second Motion to Extend Time for Filing Appellant's Brief 2

This motion for extension of time is not filed sole ly for the purposes of delay of these proceedings, but is filed because Appellant's couns el underestimated the time required to research and address the points of error relevant t o this appeal in making the original request for only an eighteen day extension. Appell ant'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 f iling. 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 rela ted estate issues, which have resulted in

a loss of time that would otherwise have been devot ed to completing the brief by the filing date. 4. This is the appellant's second motion for an ex tension of time to file appellant's brief. 5. Appellant's counsel personally conferred with c ounsel for each appellee and none oppose this additional ten-day extension. WHEREFORE, Frank Keathley, appellant, moves the Co urt to consider his motion and to grant him an extension of the time fo r 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, 20 15. /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 conf erred with counsel of record for each appellee and none opposed the motion for an ad ditional 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 ha s 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 903-885-1199Appellant'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