ACCEPTED 01-14-00301-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 1/6/2015 2:33:07 PM CHRISTOPHER PRINE CLERK NO. 01-14-00301-CV IN THE FIRST COURT OF APPEALS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS 1/6/2015 2:33:07 PM CHRISTOPHER A. PRINE Clerk DEANA POLLARD SACKS, APPELLANT vs. THOMAS F. HALL AND THOMAS F. HALL, D.D.S., M.S., P.A., APPELLEES

From the County Court at Law No. 3 of Harris County, Texas Trial Court Cause No. 919405

APPELLANT’S MOTION FOR AN EXTENSION OF TIME TO FILE REPLY BRIEF

TO THE HONORABLE JUSTICES OF THE COURT: Comes now Appellant, Deana Pollard Sacks, who respectfully moves for an extension of time in which to file her reply brief and in support would respectfully show as follows: A. Introduction 1. Appellant is Deana Pollard Sacks.

2. Appellees are Thomas F. Hall and Thomas F. Hall, D.D.S., M.S., P.A.

B. Argument and Authorities 3. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to

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4. Movant received Appellee’s Brief on December 22, 2014. Movant’s reply brief is currently due on January 9, 2015. Movant seeks an extension of 20 days. No previous extensions have been requested for this reply brief.

5. Movant’s counsels’ schedules have not allowed time to properly prepare Appellant’s reply brief due to several pending matters which included a planned family holiday vacation over Christmas and New Years, preparation for critical client depositions in a U.S. Federal court case out of the Western District of Texas, Austin Division, and co-counsel’s reply brief due in the Texas Supreme Court in Nations v. Heitkamp. Movant’s counsel and co-counsel have been involved in daily preparations for these matters, along with their normal caseload.

C. Conclusion 6. Deana Pollard Sacks, Appellant in this matter, requests the Court grant an extension of the deadline to file her reply brief until January 29, 2015. This request is not sought for delay, but so that justice may be done. The matters contained in this motion are within my personal knowledge and do not require separate verification.

D. Prayer 7. For these reasons, Deana Pollard Sacks, Appellant, asks the Court to grant an extension of time to file her reply brief until January 29, 2015.

Page 2 Respectfully submitted, /s/ Brad Beers Brad Beers SBOT: 02041400 5020 Montrose Blvd., Suite 700 Houston, Texas 77006 713-654-0700 713-654-9898 facsimile [email protected] Counsel for Deana Pollard Sacks Certificate of Conference I certify that I attempted to communicate with counsel for appellees, Gregory Travis and John Woods, over the holidays and have not heard back from them.

/s/ Brad Beers Brad Beers Certificate of Service Pursuant to Texas Rules of Appellate Procedure 6.3 and 9.5(b), (d), and (e), I certify that on January 6, 2015, a copy of this motion was mailed via facsimile service as follows: Gregory Travis Via Facsimile 713-626-3801 John Woods The Travis Law Firm Wilcrest Drive, Suite 350 Houston, Texas 77042

/s/ Brad Beers Brad Beers

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