Tommy Parker, Jr. v. Mary Martha Parrack

ACCEPTED
15-25-00075-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
9/12/2025 3:15 PM

No. 15-25-00075-CV CHRISTOPHER A. PRINE
CLERK
In the Court of Appeals FILED IN
15th COURT OF APPEALS
For the Fifteenth Judicial District Sitting at AUSTIN, TEXAS
Austin, Texas 9/12/2025 3:15:31 PM
CHRISTOPHER A. PRINE
Clerk
TOMMY PARKER, JR.
Appellant
v.
MARY MARTHA PARRACK
Appellee

Appeal from the 12th District Court of Madison County, Texas
Trial Court Cause No. 18-16110

FOURTH UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLANT’S BRIEF ON THE MERITS

Greg White Jay B. Goss
gwhite@grayreed.com Jgoss@bruhez.com
Joseph Briers
GRAY REED & MCGRAW, LLP jbriers@bruchez.com
900 Washington Ave., Suite 800
Waco, Texas 76701 BRUCHEZ & GOSS, PC
(254)342-3000 2740 Copperfield Dr.
(254) 342-3102 (fax) Suite 200
Bryan, Texas 77802
William F. Carter (979) 268-4343
wfcarterlaw@gmail.com (979) 268-5323 (fax)
201 North Main St.
Bryan, Texas 77803
(979) 779-0712
(979) 779-9243 (fax)

Attorneys for Appellant Tommy Parker, Jr.
No. 15-25-00075-CV

TOMMY PARKER, JR.
Appellant
v.
MARY MARTHA PARRACK
Appellee

FOURTH UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLANT’S BRIEF ON THE MERITS

To the Honorable Court of Appeals:

This is a Motion to Extend the Time for Filing the Appellant’s Brief on

the Merits. The Appellant (Tommy Parker, Jr.) requests an extension of time

until Wednesday, September 16, 2025.

1. The judgment in this case was signed on January 14, 2025. Parker filed

a Motion for New Trial. The Notice of Appeal was filed on April 14,

2025. The Clerk’s Record was filed on May 7, 2025. The Reporter’s

Record was filed on May 15, 2025.

2. The Appellant’s Brief was originally due on June 16, 2025.

3. Appellant requests an extension of time to file his Brief on the Merits.

The Court granted an extension of time from June 16 to July 16, 2025.

The Court granted a second extension of time from July 16 to July 28,

2025. The Court granted a third extension of time from July 28 to

August 29th. Appellant requests a final extension of time from August

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29 to September 16, 2025. The request for an extension of time is

unopposed.

4. In the Court’s Order granting the Third Extension of Time, the Court

noted that no further extensions would be permitted absent

“exceptional circumstances.” There is good cause and exceptional

circumstances for this final extension of time. The undersigned

counsel had open heart surgery in early August of 2025. Counsel

predicted, based on medical advice, that he would be able to work in

the middle to latter part of August and could finish the brief by August

29, 2025. In the course of recovery, though, counsel suffered

unanticipated complications, including fluid in the lungs that caused

painful and persistent cough (which hurts a lot more after the chest had

been sawed open), very low blood pressure, and gout in both feet

(which had to be left largely untreated because of other medication).

Recovery sufficient to do work was delayed until counsel was released

from all of the medication on September 12, 2025. Counsel has

worked September 12th and is confident that with a few more days, he

can finish editing the brief, and can do the required formatting to finish

a brief that will be helpful to the Court. These complications were

unexpected, and although counsel expected to be slow after the

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surgery, he did not expect that these complications would all occur and

that they would make work virtually impossible.

5. Counsel has conferred with opposing Counsel, and there is no

opposition to this request.

6. Parker requests that the Court extend the time for filing the Appellant’s

Brief on the Merits to September 16, 2025.

Respectfully submitted,

By: /s/ Greg White
Greg White
Texas Bar No. 21329050
gwhite@grayreed.com

GRAY REED & MCGRAW LLP
900 Washington Ave., Ste. 800
Waco, Texas 76701
Telephone: (254) 342-3000
Facsimile: (254) 342-3100

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Jay B. Goss
Texas Bar No. 08222600
Jgoss@bruhez.com
Joseph Briers
Texas Bar No. 24082730
jbriers@bruchez.com

BRUCHEZ & GOSS, PC
2740 Copperfield Dr.
Suite 200
Bryan, Texas 77802
Telephone: (979) 268-4343
Facsimile: (979) 268-5323

William F. Carter
Texas Bar No. 03932800
wfcarterlaw@gmail.com
201 North Main St.
Bryan, Texas 77803
Telephone: (979) 779-0712
Facsimile: (979) 779-9243

ATTORNEYS FOR APPELLANT TOMMY
PARKER, JR.

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Certificate of Conference

I certify that on September 12, 2025, I communicated with Laura
Upchurch, counsel for the appellee, about an extension of time to file the
Appellant’s Brief on the Merits. I told Ms. Upchurch that we would ask the
Court for an extension to Wednesday, September 16, 2025. Ms. Upchurch
promptly replied that she did not oppose the requested extension. We agreed
that the Appellant would not oppose any similar request for the Appellee’s
Brief if needed.

/s/ Greg White
Greg White

Certificate of Service

I certify that a true and correct copy of this Motion to Extend Time to File
Appellant’s Brief on the Merits was filed through an approved electronic filing
service, and that service was thereby accomplished on counsel listed below on
September, 2025.

Laura Upchurch
Upchurch & Yates, LLP
315 S. Park St.
Brenham, TX 77833
upchurch@upchurchyates.com

Attorneys for Appellee – Mary Martha Parrack

/s/ Greg White
Greg White

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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.

Greg White on behalf of Greg White
Bar No. 21329050
greg.white@texapplaw.com
Envelope ID: 105569135
Filing Code Description: Motion
Filing Description: Motion
Status as of 9/12/2025 3:21 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

William Carter 3932800 wfcarterlaw@gmail.com 9/12/2025 3:15:31 PM SENT

Steven White 21329050 gwhite@grayreed.com 9/12/2025 3:15:31 PM SENT

Jay Goss 8222600 jgoss@bruchez.com 9/12/2025 3:15:31 PM SENT

Joseph Briers 24082730 jbriers@bruchez.com 9/12/2025 3:15:31 PM SENT

Laura Upchurch upchurch@upchurchyates.com 9/12/2025 3:15:31 PM SENT