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Friday, September 5, 2014

XXXXX’s Motion for Continuance, or, in the Alternative, to Reschedule Trial

No. XXXXXXXXXX

XXXXXXXXX                                           §         XXXXXXXXXXXXX County, Texas
                                                             §
XXXXXXXXXXXXXXXX                             §         In the XXXXXXXXX Court
            XXXXXXXXXXXXXXX                   §
                                                             §
XXXXXXXX                                             §         XXXXXXX Judicial District     

XXXXX’s Motion for Continuance, or, in the Alternative, to Reschedule Trial

            Respondent XXXX moves this court to continue the setting of this case from Saturday,  the XX day of the month of XXXXXXXX, 20XX, 1:30 PM. It appears to XXXXX and her attorney Bob Mabry that a Saturday trial would be impractical.
1.
XXXXXX and Mabry are eager for trial. Mabry in particular is impressed that Your Honor wishes to burst the shackles of an ordinary Monday through Friday workweek and continue on past Friday afternoon into Saturday afternoon. Opposing counsel, pressing on with Stakhanovite passion, may find Saturdays and Sundays dusty deserts of mind-numbing inaction and wish for Saturday afternoon court sessions. Unfortunately, respondent’s counsel believes that the rest of the court personnel and the other state and county employees that make court practical are unlikely to attend the hearing, when the alternative is “beautiful back porches to sit on, beautiful sporting news to read, [and] beautiful beer to drink.”[1]
2.
Mabry respects the court’s orders. He will come to court on this matter at any place in [the county seat of] XXXXXX, at any date or time more than ten days from now of the court’s choosing unless summoned to another court with priority or unless a relevant bona fide medical emergency exists. His views contrast with his wife’s. And Mabry respectfully requests that the trial be moved away from a Saturday in the interest of domestic harmony in his home. He further regrets to inform the court that the only authority which he stands in awe and fear more than Your Honor is Mrs. Mabry.[2]
3.
This application is not sought for delay only, but that justice be done.
Wherefore, respondent XXXXXX and her counsel Bob Mabry pray for this court to continue this trial or reschedule it to someday not less than ten days later than the date of this filing and service XXXXXXXXX XX, 20XX.
Respectfully Submitted,


_____________________

[1] Sinclair Lewis, Elmer Gantry, Ch. XVII, § 2, (1927)
[2] H. Rider Haggard, She, Ch. VI, inter alia. (1886); Rumpole of the Bailey (last accessed XXXXX XXXX, 20XX)                                           

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