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, G P ROYAL, LLC, STEPHEN F.

PERKINS and S. PERKINS I NVESTMENT 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 Ap pellees 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 CLERKMOTION 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 Bri ef of Appellants on Wednesday, May 9,

2018).

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

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

a). Appellees’ Counsel, Carl David Adams, Esquire (Adams), a solo practitioner, has been requi red to devote substantial time just before and/or after the filing of the Brief of Appellants in th is Court, to the preparation and filing of a Response, in Adversar y 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 th is Court, to the preparation for, t raveling to and participating i n 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, conduc ted 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 th isMOTION OF EXTENSION OF TIME TO FILE BRIEF OF APPELLEES, Page 3. Court, to the preparation and filing of Plaintiff’s Motion to S trike Defendant’s Motion to Change V enue under Rule 257, in Kevin R. Bowden v. Textron, Inc., et al., in the 342 nd 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 th is Court, to the preparation and filing of Plaintiff’s Motion to S trike Defendant’s Motion to Reconsider Prior Venue Rulings, in the above-described Bowden v. Textr on, 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 th is 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 t he above-described Bowden v. Textron, Inc., matter, filed May 11, 2018.

f). Adams has been required to de vote substantial time just bef ore and/or after the filing of the Brief of Appellants in this Cour t, to the preparation and filing of an Application for Probate of Wil l and Issuance of Letters Testament ary, in the Estate of Roger F. Moore, Deceased (Adams’ longtim e friend and c lient 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 th is Court, to the preparation for, t raveling to and participation i n a scheduled hearing on May 24, 2018, on Plaintiffs’ Application for Post-Judgment Turn-over Re lief sought by Scott and Kristi Fisher, in the 219 th District Court of Colli n 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, Indi vidually and as Independent Executrix of the Estate of Caro l 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 ex tend, by 45 days (or until Frida y, July

20, 2018) the deadline for the f iling of their Brief as Appelle es.

5. There have been no previous exten sions requested or granted wit h

regard to the Brief of Appellees.

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

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

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 confe rred with Counsel for Appellants with respect to the foregoing Motion (i ncluding providing a copy of the Motion to Counsel for Appellants). Counsel for Appellants has stated in w riting that Appellants do not oppose the re lief requested in the Motion.

Certified to this 4 th day of June 2018 by:

/s/ Carl David Adams

______________________ Carl David Adams