ACCEPTED 03-14-00721-CV 4753444 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/2/2015 4:38:04 PM JEFFREY D. KYLE CLERK Case No. 03-14-00721-CV FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE THIRD DISTRICT OF TEXAS4/2/2015 4:38:04 PM AUSTIN, TEXAS JEFFREY D. KYLE Clerk RAUL MARTINEZ, Appellant, vs. DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES, INC., ASSET-BACKED PASS- THROUGH CERTIFICATES SERIES 2003-6; HOMEWARD RESIDENTIAL, INC. AND JUANITA STRICKLAND, Appellees.

Appealed from the 201st Judicial District Court of Travis County, Texas Cause No. D-1-GN-13-001195

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS: Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellees, Deutsche Bank National Trust Company as Trustee for Ameriquest Mortgage Securities, Inc., Asset-Backed Pass-Through Certificates Series 2003-6 and Homeward Residential, Inc. (“Appellees”) file this motion for extension of time to file Appellees’ Brief, and in support show as follows: 1. This is an appeal from the Trial Court’s order granting Appellees’ traditional and no-evidence summary judgment and denying Appellant’s traditional and no-evidence partial summary judgment, entered on or about on October 28, 2014.

2. Appellant’s brief was deemed filed on March 9, 2015.

3. Appellees’ brief is currently due on April 8, 2015. Appellees seek a day extension of time until May 8, 2015, within which to file and serve their brief and record excerpts.

4. The requested extension is not sought for purposes of delay only, but so that justice may be served in this action. Specifically, Appellees’ counsel requests an extension of time to file its brief due to the fact that the undersigned counsel has overlapping deadlines that has prevented their full attention to this case by the current response deadline.

5. As a result, Appellees’ counsel will not have sufficient time to complete preparation of Appellees’ brief by April 8, 2015. Accordingly, Appellees request an extension of time of until May 8, 2015, to file their brief so that Appellees will have an adequate time to prepare its brief.

6. This is Appellees first request for an extension of time to file its brief.

No further requests for extension of time are anticipated.

Prayer Appellees, Deutsche Bank National Trust Company as Trustee for Ameriquest Mortgage Securities, Inc., Asset-Backed Pass-Through Certificates Series 2003-6 and Homeward Residential, Inc., respectfully request that the Court grant an extension of time until May 8, 2015, within which Appellees must file and serve their brief and record excerpts in this appeal.

Respectfully Submitted, /s/ Bradley E. McLain Jeremy J. Overbey Texas Bar No. 24046570 [email protected] Bradley E. McLain Texas Bar No. 24041453 [email protected] SETTLEPOU 3333 Lee Parkway, Eighth Floor Dallas, Texas 75219 (214) 520-3300 (214) 526-4145 (Facsimile) ATTORNEYS FOR APPELLEES Certificate of Conference I hereby certify that on April 2, 2015, I conferred with counsel for Appellant on the substance of this motion, and counsel for Appellant stated he is unopposed to the motion.

/s/ Bradley E. McLain Bradley E. McLain

Certificate of Service I certify that this document was served in accordance with the Appellate Rules of Civil Procedure on April 2, 2015, by the manner indicated upon the following persons: Via Electronic Service William B. Gammon Karla Huertas Gammon Law Office, PLLC 1201 Spyglass Drive, Suite 100 Austin, Texas 78746 Attorneys for Appellant

/s/ Bradley E. McLain Bradley E. McLain

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