No. 03-15-00440-CV

Raymond Cox, Jr. and § In the Court of Appeals

Tamesa Cox, §

Appellants, §

§

v. §

§

GMAC Mortgage, LLC, §

its successors and/or assigns, §

Appellee § Third District of Texas

Appellants’ Motion to Extend Time to File Brief

To the Honorable Court:

Appellants, pursuant to the Court’s notice of November 17, 2015, request that

the Court extend time for filing of their brief under Rules of Appellate Procedure 10.5(b),

38.6(d) and all other applicable Rules, and in support of this motion show:

1. Due Date of Brief. Appellants’ Brief was originally due for filing November

12, 2015 per the Court’s last notice. Appellants seek hereby to have the due date of

their brief extended to Thursday, December 10, 2015.

2. Extension of Time Sought. Appellants have sought no previous extension

of time for filing of their brief, and ask that the Court grant them an extension for filing

of their brief until Thursday, December 10, 2015, in order that their brief may be optimally

prepared. Since October 15, 2015, Appellants’ counsel has missed considerable work

APPELLANTS’ MOTION TO EXTEND

TIME TO FILE APPELLANTS’ BRIEF

ACCEPTED

03-15-00440-CV

8018533

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/30/2015 4:01:21 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/30/2015 4:01:21 PM JEFFREY D. KYLE Clerk
time due to a chronic respiratory infection that has required a doctor’s care, and for

which counsel is still being treated. What work time was possible in the interim has

been largely absorbed with matters involving applications for emergency relief or

immovabledeadline filingsin federal or appellatematters.In addition, a death in counsel’s

wife’s family occurred near the time the brief would have regularly been due. Due to

all of the foregoing, Appellants ask that they be granted this short extension of time

to file their brief.

3. Prayer. For these reasons, your Appellants request that the Court:

(A) grant an extension of the time to file Appellants’ brief,through and

until December 10, 2015; and

(B) grant Appellants such other and further relief to which they may

be entitled or is in the interest of justice.

Respectfully submitted,

/s/ Michael Brinkley

_____________________________________

Michael Brinkley

State Bar No. 03004300

BRINKLEY LAW PLLC

P. O. Box 820711

Fort Worth, Texas 76182-0711

(817) 284-3535; metro (817) 589-7111

fax (888) 511-0946

michael@brinkleypllc.com

Attorney for Appellants

APPELLANTS’ MOTION TO EXTEND

TIME TO FILE APPELLANTS’ BRIEF 2
Certificate of Conference

I conferred by telephone todaywith Paul A.Hoefker, counselfor Appellee, who

advised me Appellee is unopposed to the relief requested.

Dated: November 30, 2015.

/s/ Michael Brinkley

_____________________________________

Michael Brinkley

Certificate of Service

I hereby certify that a true and correct copy of the foregoing has been served on the

following attorney of record, as required by Texas Rule of Appellate Procedure 9.5:

Paul A. Hoefker

ALDRIDGE | PITE, LLP

550 Westcott, Suite 560

Houston, TX 77007

713-293-3618

fax 858-412-2773

Attorney for Appellee

Dated: November 30, 2015.

/s/ Michael Brinkley

______________________________

Michael Brinkley

APPELLANTS’ MOTION TO EXTEND

TIME TO FILE APPELLANTS’ BRIEF 3