Kenneth D. McKeough v. Camelot Townhomes Association, Inc.

ACCEPTED 08-21-00026-CV EIGHTH COURT OF APPEALS EL PASO, TEXAS 11/2/2021 7:03 PM 08-21-00026-CV

ELIZABETH G. FLORES CLERK NO. 08-21-00026-CV

IN THE COURT OF APPEALS FILED IN 8th COURT OF APPEALS EIGHTH DISTRICT EL PASO, TEXAS AT EL PASO, TEXAS 11/2/2021 7:03:05 PM ELIZABETH G. FLORES KENNETH MCKEOUGH, Clerk Appellant

VS.

CAMELOT TOWNHOMES ASSOCIATION,

INC.,

Appellee.

On Appeal from the County Court at Law No. 3 of El Paso County, Texas

Cause No. 2020DCV4040 (Hon. Javier Alvarez)

APPELLANT’S AGREED MOTION FOR EXTENSION TO FILE BRIEF OF APPELLANT

TO THE HONORABLE EIGHTH COURT OF APPEALS:

Appellant’s Brief was due October 31, 2021. Appellant seeks a thirty- day extension to file the Brief November 30, 2021.

A representative sample of work occupying counsel’s time includes working on the petition for discretionary review in Cause No. PD-0769-21, Hal Honea v. State of Texas, in the Texas Court of Criminal Appeals, working on a petition for review in Cause no. 21-0883, Mark Wheeler, et al, v. Brandon Scott Free, et al, in the Supreme Court of Texas, finishing the brief in Cause No. 11-21-00126-CR, Jesus Rodriguez v. State of Texas, in the Eastland Court of Appeals, disposing of Cause No. 25,866, State of Texas vs. Shay Molenburg, in the County Court of Callahan County, Texas, and preparing for a jury trial in Cause No. 12,369, State v. Daniel Charles Jackson, in the 32nd District Court of Nolan County, Texas.

Accordingly, Counsel prays for an extension to file the Brief on November 30, 2021.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant prays this Court enters an order granting an extension to file the Brief on November 30, 2021.

Respectfully Submitted,

/s/Rick Dunbar

RICK DUNBAR

TBN: 24025336

7242 Buffalo Gap

Abilene, Texas 7966

Phone: 325/428-9450

Fax: 325/455-1912

[email protected]

CERTIFICATE OF SERVICE

I hereby certify that on this 2nd day of November, 2021, a true and correct copy of the above and foregoing was forwarded all counsel of record in a manner consistent with the requirements of the law.

/s/Rick Dunbar Rick Dunbar CERTIFICATE OF CONFERENCE

I hereby certify that on November 1, 2021, I conferred with Mr. Hugo Madrid, Counsel for Appellee. He graciously agreed to the extension.

/s/Rick Dunbar Rick Dunbar

CERTIFICATE OF COMPLIANCE

I hereby certify that according to the word count function of the undersigned’s word processing software, this document contains 363 words. The undersigned therefore certifies compliance.

/s/Rick Dunbar Rick Dunbar Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Frederick Dunbar on behalf of Rick Dunbar

Bar No. 24025336 [email protected]

Envelope ID: 58787135

Status as of 11/3/2021 8:47 AM MST

Case Contacts

Name BarNumber Email TimestampSubmitted Status Brenda JRamirez [email protected] 11/2/2021 7:03:05 PM SENT Rick Dunbar [email protected] 11/2/2021 7:03:05 PM SENT Hugo Madrid [email protected] 11/2/2021 7:03:05 PM ERROR Hugo Madrid [email protected] 11/2/2021 7:03:05 PM SENT