MOTION OF EXTENSION OF 

TIME TO FILE BRIEF OF APPELLEES, 

Page 1. 

05-17-01139-CV 

IN THE COURT OF APPEALS 

FIFTH JUDICIAL DISTRICT OF TEXAS 

AT DALLAS 

ROYAL SERVICES GROUP, LP, GP ROYAL, LLC, STEPHEN F. 

PERKINS and S. PERKINS INVESTMENT PROPERTIES, INC., 

Appellants, 

vs. 

SCOTT FISHER and KRISTI FISHER, 

Appellees. 

MOTION FOR EXTENSION OF TIME TO FILE 

BRIEF OF APPELLEES 

_____________________________________________________________ 

TO THE HONORABLE FIFTH COURT OF APPEALS: 

 NOW COMES SCOTT FISHER and KRISTI FISHER (Appellees), 

and file their Motion for Extension of Time to File Brief of Appellees and 

would respectfully show the Court the following: 

ACCEPTED

05-17-01139-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

6/4/2018 1:49 PM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 06/04/2018 1:49:31 PM LISA MATZ Clerk
MOTION OF EXTENSION OF 

TIME TO FILE BRIEF OF APPELLEES, 

Page 2. 

I. 

GROUNDS FOR MOTION 

1. Scott Fisher and his wife, Kristi Fisher, are the Appellees in the above 

entitled and numbered cause. 

2. The Brief of Appellees is presently due on Friday, June 8, 2018 (i.e. 30 

days after the filing of the Brief of Appellants on Wednesday, May 9, 

2018). 

3. For the following reasons, Appellees request an extension of time of 45 

days (or until Friday, July 20, 2018) to file their Brief of Appellees: 

a). Appellees’ Counsel, Carl David Adams, Esquire (Adams), a 

solo practitioner, has been required to devote substantial time just 

before and/or after the filing of the Brief of Appellants in this 

Court, to the preparation and filing of a Response, in Adversary 

Proceeding #17-02002-rlj, in Jerry Artho v. Happy State Bank, 

et al., in the U.S. Bankruptcy Court for the Northern District of 

Texas, Amarillo Division, filed May 7, 2018 (Artho v. Happy 

State Bank). 

b). Adams has been required to devote substantial time just 

before and/or after the filing of the Brief of Appellants in this 

Court, to the preparation for, traveling to and participating in a 

hearing lasting approximately 3 1⁄2 hours on Thursday, May 10, 

2018, in the U.S. Bankruptcy Court for the Northern District of

Texas, Amarillo Division, conducted regarding various pending 

Motions of the parties in the above-described Artho v. Happy 

State Bank matter. 

c). Adams has been required to devote substantial time just 

before and/or after the filing of the Brief of Appellants in this 
MOTION OF EXTENSION OF 

TIME TO FILE BRIEF OF APPELLEES, 

Page 3. 

Court, to the preparation and filing of Plaintiff’s Motion to Strike 

Defendant’s Motion to Change Venue under Rule 257, in Kevin 

R. Bowden v. Textron, Inc., et al., in the 342nd District Court of 

Tarrant County, Texas, filed May 8, 2018 (Bowden v. Textron, 

Inc.). 

d). Adams has been required to devote substantial time just 

before and/or after the filing of the Brief of Appellants in this 

Court, to the preparation and filing of Plaintiff’s Motion to Strike 

Defendant’s Motion to Reconsider Prior Venue Rulings, in the 

above-described Bowden v. Textron, Inc., matter, filed May 8, 

2018. 

e). Adams has been required to devote substantial time just 

before and/or after the filing of the Brief of Appellants in this 

Court, to the preparation and filing of Plaintiff’s Response to

“So-Called” Rule 257 Motion to Transfer Venue by Defendant 

Center Country Club, Inc., in the above-described Bowden v. 

Textron, Inc., matter, filed May 11, 2018. 

f). Adams has been required to devote substantial time just before 

and/or after the filing of the Brief of Appellants in this Court, to 

the preparation and filing of an Application for Probate of Will 

and Issuance of Letters Testamentary, in the Estate of Roger F.

Moore, Deceased (Adams’ longtime friend and client of over 35 

years, who died May 10, 2018, and whose Memorial Service in 

which Adams was a participant was May 30, 2018), Case #PB1-

1165-2018, in the Probate Court of Collin County, Texas, on 

June 1, 2018. 

g). Adams has been required to devote substantial time just 

before and/or after the filing of the Brief of Appellants in this 

Court, to the preparation for, traveling to and participation in a 

scheduled hearing on May 24, 2018, on Plaintiffs’ Application 

for Post-Judgment Turn-over Relief sought by Scott and Kristi 

Fisher, in the 219th District Court of Collin County, Texas, in its 

Cause #219-01665-2014, in Fisher v. Stephen F. Perkins, et al. 
MOTION OF EXTENSION OF 

TIME TO FILE BRIEF OF APPELLEES, 

Page 4. 

h). Adams is presently scheduled to begin a Jury Trial on 

Tuesday, July 10, 2018, in the case of Michael R. Herrington v.

Lisa Herrington Morgan, Individually and as Independent 

Executrix of the Estate of Carol Ann Herrington, Deceased, in 

Cause #PR-15-109A, in the County Court at Law of Rockwall 

County, Texas (and, unless the trial setting is continued, much of 

the week of July 2, 2018, which includes the Holiday of July 4,

2018, will be required to be spent in preparation for the jury trial 

in that scheduled matter). 

4. Appellees request this Court extend, by 45 days (or until Friday, July 

20, 2018) the deadline for the filing of their Brief as Appellees. 

5. There have been no previous extensions requested or granted with 

regard to the Brief of Appellees. 

6. Appellees seek this extension of time in the interest of justice and not 

to delay this matter or increase the burdens on this Court's important 

time.

 Respectfully submitted, 

 

 THE LAW OFFICES OF 

 CARL DAVID ADAMS 

6440 North Central Expressway 

 Suite 505 

 Dallas, Texas 75206 

 (214) 468-3032 phone 

 (214) 871-5090 fax 

 /s/ Carl David Adams 

 ____________________ 
MOTION OF EXTENSION OF 

TIME TO FILE BRIEF OF APPELLEES, 

Page 5. 

 Carl David Adams 

 State Bar #00850600 

 carldavidadams@hotmail.com 

ATTORNEY FOR APPELLEES, 

SCOTT and KRISTI FISHER 

CERTIFICATE OF CONFERENCE 

Counsel for Appellees has conferred with Counsel for Appellants with 

respect to the foregoing Motion (including providing a copy of the Motion to 

Counsel for Appellants). Counsel for Appellants has stated in writing that 

Appellants do not oppose the relief requested in the Motion. 

 

 Certified to this 4th day of June 2018 by: 

 

/s/ Carl David Adams 

 ______________________ 

 Carl David Adams