ACCEPTED 06-14-00036-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 2/2/2015 11:42:52 AM DEBBIE AUTREY CLERK

APPELLATE CASE NO. 06-14-00036-CV

FRANK KEATHLEY, INDIVIDUALLY IN THE COURT OF APPEALS FILED IN AND DOING BUSINESS AS TOP SHELF 6th COURT OF APPEALS ANTIQUES, APPELLANT TEXARKANA, TEXAS 2/2/2015 11:42:52 AM V. FOR THE SIXTH DISTRICT DEBBIE AUTREY Clerk J.J. INVESTMENT COMPANY, LTD., ET AL AND CORBITT BAKER, APPELLANTS TEXARKANA, TEXAS

SECOND MOTION TO EXTEND TIME FOR FILING APPELLANT'S BRIEF

TO THE HONORABLE COURT OF APPEALS:

Frank Keathley, individually and doing business as Top Shelf Antiques, appellant,

moves this Court to grant him an extension of time to file Appellant's Brief and

respectfully states as follows:

1. This appeal is from post-judgment orders entered by the trial court in

Cause No. 10,072 pending in the 62nd Judicial District Court of Franklin County, Texas,

signed March 25, 2014. All matters pending in the trial court were stayed by Appellant's

bankruptcy until this appeal was reinstated by order of this Court dated October 15, 2014

following Appellant's discharge in bankruptcy.

2. The Appellant's Brief for Frank Keathley was originally due January 15,

2015. The filing date was previously extended to today, February 2, 2015. This motion

is filed as a request for extension of the filing date for an additional ten days until

February 12, 2015. If granted, the filing date for Appellant's brief will have been

extended for a total of 28 days total.

3. For good cause shown, Frank Keathley files this motion seeking a ten-day

extension for filing his Appellant's Brief from February 2, 2015 to February 12, 2015.

Appellant's Second Motion to Extend Time for Filing Appellant's Brief 1 This motion for extension of time is not filed solely for the purposes of delay of these

proceedings, but is filed because Appellant's counsel underestimated the time required to

research and address the points of error relevant to this appeal in making the original

request for only an eighteen day extension. Appellant's counsel currently has two

responses to petitions for review that are or will be pending in the Supreme Court and one

additional case pending for appeal to the Court of Appeals that have also required

research hours for preparation or in response for filing. On last Thursday, Mr. Keathley

advised the undersigned counsel of the death of his Mother and requested legal assistance

with respect to the death, the funeral and the related estate issues, which have resulted in

a loss of time that would otherwise have been devoted to completing the brief by the

filing date.

4. This is the appellant's second motion for an extension of time to file

appellant's brief.

5. Appellant's counsel personally conferred with counsel for each appellee

and none oppose this additional ten-day extension.

WHEREFORE, Frank Keathley, appellant, moves the Court to consider his

motion and to grant him an extension of the time for filing his Appellant's Brief from

February 2, 2015 to no later than February 12, 2015, or such other time as the Court may

deem appropriate.

Appellant's Second Motion to Extend Time for Filing Appellant's Brief 2 Respectfully submitted this 2nd day of February, 2015.

/s/ Larry R. Wright Larry R. Wright State Bar No. 22048000 P.O. Box 144 406 South Main Street Winnsboro, Texas 75494 Telephone 903-342-1089 Fax 903-342-1088 E-mail [email protected]

CERTIFICATE OF CONFERENCE

This is to certify that counsel for appellant conferred with counsel of record for

each appellee and none opposed the motion for an additional extension.

Signed this 2nd day of February, 2015.

/s/ Larry R. Wright Larry R. Wright

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing has been this day served on each

attorney of record, as follows:

Travis P. Clardy Clardy Law Office 209 E. Main St. Nacogdoches, TX 75961 By fax to 936-564-2507

Larry Blount Powers & Blount, LLP PO Box 877 Sulphur Springs, TX 75483 By fax to 903-885-1199

Appellant's Second Motion to Extend Time for Filing Appellant's Brief 3 Gene Stump PO Box 606 Mount Vernon, TX 75456 By fax to 903-588-2272

Signed this 2nd day of February, 2015.

/s/ Larry R. Wright Larry R. Wright

Appellant's Second Motion to Extend Time for Filing Appellant's Brief 4