Magdalena Sanchez McMordie, in Her Capacity as Beneficiary and Co- Trustee of the Hobart B. McMordie, II Asset Management Trust. v. Charles Harris McMordie, in His Capacity as Co-Trustee of the Hobart B. McMordie, II Asset Management Trust

ACCEPTED 07-14-00393-CV SEVENTH COURT OF APPEALS AMARILLO, TEXAS 7/29/2015 11:56:57 AM Vivian Long, Clerk

NO. 07-14-00393-CV

IN THE COURT OF APPEALS

FILED IN

FOR THE SEVENTH DISTRICT OF TEXAS AT AMARILLO

7th COURT OF APPEALS AMARILLO, TEXAS MAGDALENA MCMORDIE, 7/29/2015 11:56:57 AM in her capacity as Beneficiary and Co-Trustee VIVIAN LONG CLERK of the Hobart B. McMordie, II Asset Management Trust Appellant/Cross Appellee, v.

CHARLES HARRIS MCMORDIE, in his capacity as Co-Trustee of the Hobart B. McMordie, II Asset Management Trust Appellee/Cross-Appellant.

FROM THE 251ST DISTRICT COURT

RANDALL COUNTY, TEXAS

THE HONORABLE ANA ESTEVEZ, JUDGE PRESIDING

CAUSE NO. 66,482-C

UNOPPOSED MOTION FOR EXTENSION OF TIME

TO FILE MOTION FOR REHEARING TO THE HONORABLE COURT OF APPEALS:

Charles Harris McMordie (“Charles”) files this Unopposed Motion for Extension of Time to File Motion for Rehearing, and in support thereof shows the Court the following:

I.

DUE DATE

Charles’ Motion for Rehearing is currently due on August 8, 2015. Charles seeks an additional twenty (20) days, until August 28, 2015, to file his Motion for Rehearing.

II.

REASONS FOR EXTENSION OF TIME

Charles’ counsel is involved in a number of other matters with deadlines and settings that will interfere with Charles’ ability to timely file his Motion for Rehearing.

III.

EXTENSION SOUGHT IN THE INTEREST OF JUSTICE The extension sought is not for the purpose of delay, but rather, is sought in the interest of justice and to allow Charles to fully brief issues to the Court.

IV.

APPELLANT/CROSS-APPELLEE AGREES TO THIS REQUEST Counsel for Appellant/Cross-Appellee, Slater C. Elza, does not oppose this motion for extension of time.

V.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Charles Harris McMordie prays that the Court grant an extension of time of twenty (20) days, until August 28, 2015, to file his Motion for Rehearing.

Respectfully submitted,

/s/ David J. Drez III David J. Drez III State Bar No. 24007127 [email protected] Meredith L. Perry State Bar No. 24075622 [email protected] WICK PHILLIPS GOULD & MARTIN LLP

100 Throckmorton Street, Suite 550 Fort Worth, Texas 76102 Telephone: 817.332.7788 Telecopier: 817.332.7789 Scott W. Sherwood State Bar No. 18255250 Sherwood and Sherwood Euclid Street Panhandle, Texas 79068 Telephone: 806.537.3591 Telecopier: 806.537.3592 ATTORNEYS FOR APPELLEE/ CROSS-APPELLANT CHARLES HARRIS MCMORDIE

CERTIFICATE OF CONFERENCE

On July 28, 2015, I contacted counsel for Appellant/Cross-Appellee, Slater C. Elza, and Appellant/Cross-Appellee is not opposed to this Motion.

/s/ David J. Drez III David J. Drez III CERTIFICATE OF SERVICE

A true copy of the foregoing document was served on the following counsel of record via electronic filing, on this 29th day of July, 2015: Slater C. Elza

Jennie C. Knapp

UNDERWOOD LAW FIRM, P.C.

P.O. Box 9158

Amarillo, Texas 79105

/s/ David J. Drez III David J. Drez III