# CASE NO. 06-14-00094-CV

______________________________ _______________________________ IN THE SIXTH COURT OF APPEALS TEXARKANA, TEXAS

______________________________ _______________________________ Nancy Bowman, Appellant,

vs. Jerry Davidson and Diana Davidson, Appellees.

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________________ ______________ On Appeal from the 71st Judicial District Harrison County, Texas Cause No. 13-0618 The Honorable Brad Morin, Presiding

________________________________ ____________________________ UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

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________________ ______________ TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW NANCY BOWMAN, Appella nt in the above-referenced cause, who makes and files this , her Unopposed Motion to Extend Time to File Appellant’s Brief pursuant to Texas Rules of Appellate Procedur e 10.5, and in support whereof would respectfully show unto the Honorable Cour t as follows: ACCEPTED 06-14-00094-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 3/3/2015 5:45:30 PM DEBBIE AUTREY

CLERK2 I. Background Appellant filed her Notice of App eal and immediately requested the preparation of the clerk and reporter’s records in this matter. However, there was a delay in getting the records filed and obtaining copies of the record due to the closing of the courts because of the inclement weather. Furthe r, it has now come to the Appellant’s attention that there may be documents missin g from the Clerk’s Record and Supplemental Record f iled later by the Clerk. Appel lant is working diligently to resolve the issues but she needs additional time to file her brief as a result. The current due date for Appellant’s Brief is March 9, 2015. A ppellant requests an extension of the d eadline in order to allow additio nal time for the preparation of her brief with the benefit of a complete Clerk’s Record. This is the first request for an extension ma de by Appellant in this matter

. II. Grounds The following facts are relied upon by Appellant to reasonably explain the need for the requested extension and provide the Court with goo d cause: The Clerk’s Record was not complete when filed. Appellant has not been able to obtain a bate-stamped copy of the Supplemental Record t o date due to the3 court’s closing because of inclement weather, and Appellant nee ds to make sure all relevant documents are include d in the Clerk’s Record and Suppl emental Record before she can cite to the doc uments and file her brief. Thus, Appellant requests an extension of time in order to prepa re her brief based on a complete Clerk’s Record.
III. Relief Requested Accordingly, Appellant requests the Court grant her an extensio n of thirty (30) days to file her Appellant’s Brief from the current due da te of March 9, 2015. The undersigned has conferred w ith the Appellees’ attorney, and he has indicated he does not oppose the relie f sought in this Motion.
IV. Prayer Appellant prays the Honorable Cour t GRANT her request to extend the deadline for filing the Appellant ’s Brief as set forth herein. Appellant prays for such other a nd further relief, general or s pecial, in law or in equity, to which she may sho w herself to be justly entitled.4 Respectfully submitted, /s/Jack M. Sanders, Jr JACK M. SANDERS, JR. 109 East Houston Street P.O. Box 1387 Marshall, Texas 75671-1387 (903) 935-7172 (903) 938-8616 (Fax) sanders.jack@sbcblobal.net
ATTORNEY FOR APPELLANT

CERTIFICATE OF CONFERENCE The undersigned hereby certifies th at, has conferred with the a ttorney of record for Appellees regarding this Motion, and that he does no t oppose the relief requested herein.

/s/Jack M. Sanders, Jr. Jack M. Sanders, Jr.

CERTIFICATE OF SERVICE The undersigned hereby certifies th at, pursuant to Texas Rules of Appellate Procedure 6.3, a true and correct copy of the foregoing Motion to Extend has been sent to the following counsel of record for Appellees by postag e prepaid certified mail, return receipt requested on this, the 3rd day of March, 2015.

/s/Jack M. Sanders, Jr. Jack M. Sanders, Jr.