In the Estate of Ambrose Zachariah Bless v. the State of Texas

ACCEPTED
05-25-00650-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
8/21/2025 11:38 AM
RUBEN MORIN
CLERK

No. 05-25-00650-CV

FILED IN
5th COURT OF APPEALS
IN THE FIFTH COURT OF APPEALS DALLAS, TEXAS
DALLAS, TEXAS 8/21/2025 11:38:43 AM
Ruben Morin
___________________________________________ Clerk

MICHAEL R. BLESS AND PATRICIA BLESS,
Appellants,

v.

JENNIFER LEIGH WALLACE,
Appellee.
___________________________________________

ON APPEAL FROM PROBATE COURT NO. 2
OF DALLAS COUNTY, TEXAS
TRIAL COURT CAUSE NO. PR-23-01747-2
HON. INGRID M. WARREN, JUDGE PRESIDING
___________________________________________

UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ BRIEF
___________________________________________

TO THE HONORABLE COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.5 and 38.6(d), Appellants, Michael R. Bless

and Patricia Bless, file this Unopposed Motion for Extension of Time to File

Appellants’ Brief.

Appellees’ Brief is currently due August 22, 2025.
Counsel for Appellants requests a 45-day extension of time to file the brief,

making the brief due on Monday, October 6, 2025. This is the first request for an

extension of time to file Appellants’ Brief.

Counsel for Appellants needs additional time to prepare the Brief. Due to

numerous other deadlines, mediations and hearings, Counsel for Appellants has not

had sufficient time to finalize this Brief. This extension is not sought for delay, but

so that justice may be done.

PRAYER FOR RELIEF

For the reasons set forth above, Appellants request that this Court grant their

Unopposed Motion for Extension of Time to File Appellants’ Brief up to and

including Monday, October 6, 2025.

Respectfully submitted,

STEPTOE & JOHNSON PLLC

By:
_________________________________
William C. Ferebee
State Bar No. 06907500
bill.ferebee@steptoe-johnson.com
Catherine V. Funkhouser
State Bar No. 24031703
cate.funkhouser@steptoe-johnson.com
1780 Hughes Landing Boulevard, Suite 750
The Woodlands, Texas 77380
281.203.5700
ATTORNEYS FOR APPELLANTS, MICHAEL
R. BLESS AND PATRICIA BLESS

Page | 2
CERTIFICATE OF CONFERENCE

I hereby certify that I conferred J. Michael Young and Lawence J. Praeger,
counsel for Appellee, and Appellee’s counsel is unopposed to Appellants’ Motion
for Extension of Time to File Brief.

____________________________________
Catherine V. Funkhouser

CERTIFICATE OF SERVICE

Pursuant to Rule 9.5 of the Texas Rules of Appellate Procedure, I certify that
the Unopposed Motion for Extension of Time to File Appellants’ Brief has been
electronically filed with the Clerk of the Fifth Court of Appeals, and true and
correct copies of same have been electronically served, on this the 21st day of
August, 2025, correctly addressed as follows:

J. Michael Young
707 W. Washington
Sherman, Texas 75092
myoung@wynnesmithlaw.com

Lawrence J. Praeger
2608 State Street
Dallas, Texas 75204
lawfirmi@praegerlaw.com
Attorneys for Appellee,
Jennifer Leigh Wallace

____________________________________
William C. Ferebee

Page | 3
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.

Tracey Tarvin on behalf of William Ferebee
Bar No. 6907500
tracey.tarvin@steptoe-johnson.com
Envelope ID: 104669659
Filing Code Description: Motion
Filing Description: Appellants' Motion for Extension to File Brief
Status as of 8/21/2025 11:43 AM CST

Associated Case Party: MichaelR.Bless

Name BarNumber Email TimestampSubmitted Status

Catherine V.Funkhouser cate.funkhouser@steptoe-johnson.com 8/21/2025 11:38:43 AM SENT

Donna Yarborough donna.yarborough@steptoe-johnson.com 8/21/2025 11:38:43 AM SENT

William Ferebee bill.ferebee@steptoe-johnson.com 8/21/2025 11:38:43 AM SENT

Associated Case Party: JenniferLeighWallace

Name BarNumber Email TimestampSubmitted Status

Lawrence Praeger lawfirm@praegerlaw.com 8/21/2025 11:38:43 AM SENT

J. MichaelYoung myoung@wynnesmithlaw.com 8/21/2025 11:38:43 AM SENT