1 No. 03-15-00083-CV

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In the Third District Court of Appeals

Houston, Texas

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CRAIG A. WASHINGTON, Appellant,

vs. COMMISSION FOR LAWYER DISCIPLINE,

Appellee.

___________________________________________________________ UNOPPOSED MOTION OF CRAIG A. WASHINGTON TO EXTEND DEADLINE FOR PRINCIPAL BRIEF

___________________________________________________________ Appellant Craig A. Washington asks that this Court extend for thirty (30) days the deadline for the filing of his principal brief as the appellant in the above-captioned case, making the new briefing deadline August 3, 2015. In support Mr. Washington states:
1. This is an appeal from a final judgment signed January 8, 2015. The completed clerk’s record was filed June 2, 2015, and the reporter’s record was filed May 15, 2015. Therefore, the principal brief of the appellant is due July 2,
2015. T EX
. R. A PP
. P. 38.6(a). This court can extend that deadline. Id. 38.6(d). This is the appellants’ first request to extend the deadline, and it is unopposed. ACCEPTED 03-15-00083-CV 5595846 THIRD COURT OF APPEALS

AUSTIN, TEXAS 6/9/2015 10:06:51 AM JEFFREY D. KYLE

CLERK2

2. Counsel for Mr. Washington, John MacVane, will be responsible for the initial drafting of the brief and has a long-scheduled vacation the week of July 2. In addition, Mr. MacVane has significant responsibility for the drafting of a brief due June 23, 2015, a week before Mr. Washington’s deadline in this case. That brief, due in Crimson Exploration, Inc., et al. v. Magnum Producing, LP, No.12-15-13, in the Thirteenth Court of Appeals, involves a complex appeal of an oiland-gas title dispute with a 4,265 page clerk’s record.
3. In order to adequately focus on the briefing in this case and to accommodate Mr. MacVane’s other briefing obligations and long-standing vacation plans, Mr. Washington requests a 30-day extension of the deadline for his appellant’s brief. A 30-day extension of the briefing deadline would make appellants’ brief due on Monday, August 2, 2015.3 Request for Relief For the above reasons, Craig A. Washington asks this Court to extend for 30 days the deadline for the filing of his principal brief in this appeal, making the new deadline August 3, 2015. Respectfully submitted, /s/ John MacVane Michael A. Stafford Texas Bar No. 18996970 Katharine David Texas Bar No. 24045749 John MacVane Texas Bar No. 24085444 Gardere Wynne Sewell LLP 1000 Louisiana, Suite 3400 Houston, Texas 77002-5007 Tel: 713.276.5500 Fax: 713.276.5555 mstafford@gardere.com kdavid@gardere.com jmacvane@gardere.com
ATTORNEYS FOR CRAIG A. WASHINGTON, APPELLANT4 CERTIFICATE OF SERVICE I certify that a copy of this document was served on June 9, 2015, by delivery to the following counsel via the Electronic Filing Manager: Cynthia Canfield Hamilton Office of the Chief Disciplinary Counsel State Bar of Texas Post Office Box 12487 Austin, Texas 78711 chamilton@texasbar.com
/s/ John MacVane John MacVane



### Certificate of Conference The parties’ counsel have conferred regarding the relief requested in this motion. Counsel for the appellee—Commission for Lawyer Discipline— indicated that it will not oppose this request for relief.
/s/ John MacVane John MacVane

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