Maribel Hill v. Dwight L. Hill

ACCEPTED 15-25-00051-cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/22/2025 3:30 PM NO. 15-25-00051-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS In the Court of Appeals 15th Judicial District of TexasAUSTIN, TEXAS at Austin, Texas 9/22/2025 3:30:07 PM CHRISTOPHER A. PRINE Originating out of the Fifth Court of Appeals for the State of Texas Clerk at Dallas, Texas

MARIBEL L. HILL Appellant vs. DWIGHT L. HILL Appellee

On Appeal from the 302nd Judicial District Court, Dallas County, Texas Cause No. DF-22-14398 (Hon. Sandra Jackson, Judge Presiding)

AGREED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS: Appellee, Dwight L. Hill, files this Agreed Motion for Extension of Time to File Appellee’s Brief under Texas Rules of Appellate Procedure 10.1, 10.5(b) and 38.6(d). In support of this motion, Appellee would show the following:

Agreed Motion for Extension of Time to File Appellee’s Brief Page 1 1. This is an appeal from a Decree of Divorce. Appellant’s Brief was filed on August 21, 2025, after one extension.

2. Under the current schedule, Appellee’s Brief is due September 22, 2025.

Appellee requests a forty-five (45) day extension of time to file his Brief, such that Appellee’s deadline to file his Brief would be extended to Thursday, November 6, 2025.

3. This is Appellee’s first request for an extension of time for the filing of his Brief.

4. Counsel for Appellant has agreed to this requested extension.

5. Appellee’s counsel’s paralegal has been away from the office for three weeks during the last thirty days.

6. Appellee’s request for extension is reasonable under the circumstances.

Appellee seeks this extension in the interests of justice and judicial economy, not for purposes of delay or because of any intentional or deliberate failure by Appellee or his counsel to comply with the appellate rules.

WHEREFORE, PREMISES CONSIDERED, Appellee, Dwight L. Hill moves this Court for an order granting an agreed-upon extension of time to file Appellee’s Brief of forty-five (45) days from the currently scheduled deadline of September 22, 2025, to Thursday, November 6, 2025, and for such other and further relief to which Appellee shows himself justly entitled.

Respectfully submitted, ORSINGER, NELSON, DOWNING & ANDERSON, LLP Soledad, Suite 550 San Antonio, Texas 78205 Agreed Motion for Extension of Time to File Appellee’s Brief Page 2 Telephone: (210) 225-5567 By: /s/ Richard R. Orsinger Richard R. Orsinger State Bar No. 15322500 E-mail: [email protected] EPSTEIN FAMILY LAW, P.C.

5949 Sherry Lane Ste. 1070 Dallas, Texas 75225 Telephone: (972) 232-7673 Robert Epstein State Bar No. 24065206 E-mail: [email protected] Attorneys for Dwight L. Hill, Appellee CERTIFICATE OF CONFERENCE I hereby certify that I communicated with Marisol Lopez, counsel for Appellant, and she has agreed to the extension requested.

/s/ Richard R. Orsinger Richard R. Orsinger CERTIFICATE OF SERVICE I certify that on September 22, 2025, I served a copy of the foregoing Agreed Motion for Extension of Time to File Appellee’s Brief, on the parties listed below by E-Service and email: ATTORNEYS FOR APPELLANT Maribel L. Hill: Marisol Lopez State Bar No. 24050952 Agreed Motion for Extension of Time to File Appellee’s Brief Page 3 [email protected] MARISOL LOPEZ LAW FIRM W. Avenue D Garland, TX 75040 Telephone (972) 205-1110 /s/ Richard R. Orsinger Richard R. Orsinger Attorney for Appellee

Agreed Motion for Extension of Time to File Appellee’s Brief Page 4 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.

Richard Orsinger on behalf of Richard Orsinger Bar No. 15322500 [email protected] Envelope ID: 105916979 Filing Code Description: Motion - Exempt Filing Description: Agreed Motion for Extension of Time to File Appellee's Brief Status as of 9/22/2025 3:40 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Robert Epstein 24065206 [email protected] 9/22/2025 3:30:07 PM SENT Richard Osinger [email protected] 9/22/2025 3:30:07 PM SENT Marisol Lopez [email protected] 9/22/2025 3:30:07 PM SENT