`10:36:34 AM
`CASE NUMBER: S-23-0295
`
`IN THE SUPREME COURT
`STATE OF WYOMING
`SHAWNA GOETZ, CLERK
`
`FILED
`March 12, 2024
`CASE NUMBER: S-23-0295
`
`IN THE SUPREME COURT, STATE OF WYOMING
`
`STEPHANIE KAY TATE,
`
`Appellant
`(Petitioner),
`
`JOEL THOMASTATE,
`
`Appellee
`(Defendant).
`
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`
`S-23-0295
`
`
`
`APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIMETO FILE
`BRIEF
`
`
`
`COMES NOW, Appellee Joel Thomas Tate (“Appellee”), by and through
`
`undersigned counsel Alexandra Mijares Nash, and pursuant to W.R.A.P. 7.10
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`hereby respectfully moves this Court for an order extending time for Appellee to
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`file his brief. In support of this motion, Appellee states as follows:
`
`1.
`
`2.
`
`3,
`
`Appellant's brief wasfiled on January 31, 2024.
`
`Appellee’s brief is currently due on March 18, 2024.
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`Concurrently pending with this appeal is a Second Verified Petition
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`for Modification of Child Custody, Child Visitation, and Child Supportfiled by
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`the Appellant in the District Court of the Ninth Judicial District In and For Teton
`
`
`
`4.
`
`In an effort to reach a global resolution, the parties participated in
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`mediation on March 1, 2024, and were able to reach an agreement. Theparties are
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`now in the process of finalizing the terms of the agreement and reducingit to
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`writing to then be submitted to the District Court.
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`5.
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`Undersigned counsel therefore believes there is good cause for the
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`requested extension to allow the parties to dedicate resources to finalizing their
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`agreement which will ultimately result in the voluntary dismissal of this appeal.
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`6.
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`Appellee therefore respectfully requests a
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`twenty-one (21) day
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`extensiontofile his brief, making the brief due on or before Monday, April 8, 2024.
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`7.
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`Counsel for Appellee has conferred with counsel for Appellant
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`regarding this motion andis informed that Appellant’s counsel does not oppose
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`the relief sought herein.
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`8.
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`The extension requested will not substantially prejudice any party
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`herein.
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`WHEREFORE,Appellee requests entry of an order granting additional time
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`to file his brief, through and including April 8, 2024.
`Respectfully submitted this (day of March, 2024.
`
`
`
` Alexandra Mijares Nas
`
`WSB#7-6037
`DeFazio Law Office, LLC
`172 Center Street, Suite 203
`P.O. Box 4877
`Jackson, Wyoming 83001
`ali@defaziolaw.com
`Attorney for Appellee
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing Appellee’s Unopposed Motion for Extension
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`of Time to File Briefwas served electronically via the Wyoming Supreme Court C-
`Track Electronic Filing System (CTEF)this | (aa day of March, 2024, to the
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`following:
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`Anna Reeves Olson
`Attorney for Appellant
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`I have accepted the termsfore-filing and hereby certify the foregoing
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`document, as submitted in electronic form,is an exact version of the paper copy
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`filed with the Wyoming Supreme Court Clerk and has been scannedfor viruses
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`andis free of viruses. Additionally,I certify that all required privacy redactions
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`have been made, and with the exception of those redactions, every document
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`submitted in digital form is an exact version of the paper copyfiled with the
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`Wyoming Supreme Court Clerk.
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