ACCEPTED 05-18-00476-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 6/5/2018 2:04 PM LISA MATZ CLERK

NO. 05-18-00476-CV LYNDA BLISS, § FIFTH DISTRICTFILED IN 5th COURT OF APPEALS Appellant, § DALLAS, TEXAS § 06/05/2018 2:04:41 PM vs. § COURT OF APPEALS LISA MATZ § Clerk Bank of America, N.A. AND § SANTANDER BANK, N.A., § Appellees. § AT DALLAS, TEXAS APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Appellant Lynda Bliss ("Bliss" or Appellant") submits this unopposed motion requesting the Court to extend the time to file Appellant's Brief.

Appellant's Brief is currently due on June 6, 2018. There have been no previous extensions of this briefing deadline.

Appellant's counsel, Jeffrey R. Sandberg of the lawfirm Palmer & Manuel, LLP, is unable to file Appellant's Brief on or before this deadline.

On May 21, 2018, Mr. Sandberg filed the Appellant's Reply Brief in this Court in WWLC Investment, L.P. v. Miraki in appellate cause 05-17-01126-CV. On May 21, 2018, Mr. Sandberg filed Petitioners' Reply to the Response to the Petition for Review in the Texas Supreme Court in appellate cause 18-0144. Additionally, Mr. Sandberg was the sole counsel for a five-day jury trial in May 2018.

Because of this, Mr. Sandberg is unable to file Appellant's Brief on or before June 6, 2018, and Appellant requests additional time to file Appellant's Brief. At this time, Appellant requests an additional thirty days to file Appellant's Brief, or a new deadline of July 6, 2018.

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3 1:\18042\Appeal\Motion (Unopposed) to Extend Time to File Appellant Brief.180605 .. doc This motion is filed before the date Appellant's Brief is due on June 6, 2018. See TEX. R. APP. P. 10.5.

PRAYER For the above reasons, Appellant asks the Court to grant an extension of time to file Appellant's Brief in this cause an additional thirty days, extending the time for Appellant to file Appellant's Brief to July 6, 2018.

Respectfully submitted, PALMER & MANUEL, PLLC By: /s/ Jeffrey R. Sandberg Jeffrey R. Sandberg State Bar No. 00790051 [email protected] 8350 N. Central Expressway; Suite 1111 Dallas, Texas 75206 (214) 242-6444/ (214) 265-1950- Fax COUNSEL FOR APPELLANT LYNDA BLISS CERTIFICATE OF CONFERENCE Counsel certifies that on June 4, 2018, counsel conferred with Appellees' counsel regarding this motion and Appellees do not oppose the relief requested by Appellant.

/s/ Jeffrey R. Sandberg JEFFREY R. SANDBERG

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 2 of 3 1:\18042\Appeal\Motion (Unopposed) to Extend Time to File Appellant Brief.180605 .. doc VERIFICATION STATE OF TEXAS § § COUNTY OF DALLAS § BEFORE ME, the undersigned Notary Public, on this day personally appeared Jeff Sandberg, who, after being duly sworn, stated under oath stated that he has read the above document; that he is authorized to execute this Verification, and that every factual statement contained therein is within his personal le e and is true and correct.

SUBSCRIBED AND SWORN T BEFORE ME on the 5th day of June, 2018, to certify which witness my and official seal.

MARIA ISLAS A lifu ~ r21lt.S Notary ID #6532246 My Commission Expires Notary Public in and for the State of Texas September 7, 2021

CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing has been forwarded to the following counsel of record in accordance with the Texas Rules of Appellate Procedure via electronic filing and email on this the 5th day of June, 2018: Kathryn B. Davis, Esq.([email protected]) Connie Flores Jones, Esq.([email protected]) Winston & Strawn LLP 1111 Louisiana 25th Floor Houston, TX 77002 /s/ Jeffrey R. Sandberg Jeffrey R. Sandberg

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3 1:\18042\Appeal\Motion (Unopposed) to Extend Time to File Appellant Brief.180605 .. doc