ACCEPTED 06-15-00129-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 10/26/2015 8:50:48 AM DEBBIE AUTREY CLERK

No. 06-15-00129-CR

§ FILED IN 6th COURT OF APPEALS James Cunningham, § IN THE TEXARKANA, TEXAS Appellant, § APPEALS,8:50:48 AM COURT OF10/26/2015 § DEBBIE AUTREY v. § FOR THE Clerk § State of Texas, § SIXTH JUDICIAL DISTRICT, Appellee. § TEXARKANA, TEXAS

MOTION TO EXTEND TIME TO FILE BRIEF

Appellant, James Barcard Cunningham, seeks an extension of time to file his brief

in this appeal and in support would show the Court:

Appellant timely perfected appeal from the June 18, 2015, judgment of the trial

court. The record was complete on August 20, 2015, the deadline for Appellant’s brief

was extended until October 21, 2015.

Appellant seeks an extension of 30 days to file his brief, making the brief due

November 20, 2015. Appellant needs additional time to file his brief because counsel for

Appellant is counsel prosecuting or defending the following matters with deadlines during

the time for preparing Appellant’s brief:

McKenna v. Caldwell, Walker Co. No. 25035 Prepared for jury trial set for October 20, 2015

Rivera v. Audi AG and Volkswagen Group of America, Bexar Co. No. 2013-CI-00118 Prepared and presented multiple motions and responses to motions for summary judgment, Robinson challenges for hearings conducted over several days the week of October 19, 2015. Sun Belt Transportation v. Lear Corporation, S.D. TX. No 5:14-CV-00043 Prepare briefing for federal district court on stay of proceeding in multi- party diversity suit. October 22, 2015

Appellant has requested one previous extension.

Prayer

For the reasons set out herein, appellant prays the Court grant an extension to file

his brief until November 20, 2015.

Respectfully submitted,

_/s/__Clint Sare_____ Clint F. Sare Tex. Bar No. 00788354 P.O. Box 1694 Bryan, Texas 77806 (979) 822-1505

Attorney for appellant James Cunningham

Certificate of Service

I certify a copy of appellant’s Motion to Extend Time to File Brief was served on Doug Howell, 300 E. 26th Street Ste. 310, Bryan, 77803 on October 26, 2015.

__/s/__Clint Sare_________ Clint F. Sare