Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 2/4/2015 10:52:45 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00552-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 2/4/2015 10:52:45 AM CHRISTOPHER PRINE CLERK 01-14-00552-CV In the First Court of Appeals Houston, Texas M ARIBEL A MBRIZ M ARTINEZ , G UADALUPE M OTA , AND R OSA N ELLY T REVINO , Appellants, V .
A LFREDO G ONZALEZ , Appellee.
S E C O N D U N O P P O S E D M O T I O N F O R E X T E N S I O N O F T I M E T O F I L E A P P E L L E E ’ S B R I E F CARL J. KOLB
State Bar No. 11660480
carl@carlkolblaw.com
C A R L J . K O L B , P . C .
925 Chulie Drive
San Antonio, Texas 78216
Telephone: (210) 225-6666
Facsimile: (210) 225-2300
ELIZABETH CONRY DAVIDSON
Of Counsel
conrydavidson@gmail.com
925 Chulie Drive
San Antonio, Texas 78216
Telephone: (210) 380-4899
Facsimile: (210) 225-2300
C o u n s e l f o r A p p e l l e e *2 TO THE HONORABLE JUDGES OF THIS COURT:
Appellee, Alfredo Gonzalez respectfully presents this Second
Unopposed Motion for Extension of Time to file his Appellee’s Brief in this
matter, requesting that the time to file the Brief be extended by thirty days
from February 4, 2015 until March 6, 2015 as allowed by T EX . R. A PP . P.
10.5(b) and 38.6. In support of this Motion, Appellee would show the Court
as follows:
The Appellants filed their Brief in this case on December 5, 2014,
making the Appellee’s Brief due on January 5, 2015, which was extended to
February 4, 2015. Due to the litigation, work and vacation schedule of
counsel for Appellee, a second thirty-day extension of time is sought to file
the Brief, up until March 6, 2015. This extension of time is not sought for
delay, but only so that justice may be done.
The numerous matters that the undersigned must attend to in their
law practices on a daily basis make it so that they will be unable to
complete the response requested in this case by the current due date.
Consequently, the Appellee respectfully requests an extension of time for
thirty (30) days, up through and including March 6, 2015.
This is the Appellee’s second request for an extension of time to file
the motion.
The undersigned counsel for Appellee has conferred with counsel for
the Appellant, Michael J. Murray, and he has indicated he is unopposed to
the extension.
Consequently, based on the foregoing, Appellee respectfully requests
an extension of time to file the Appellee’s Brief in this case for thirty days,
so that filing March 6, 2015 will be considered timely. This extension of
time is not sought for delay, but only so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, Appellee prays that this
Court will grant the extension requested above.
Respectfully submitted, CARL J. KOLB, P.C.
Carl J. Kolb Conry Davidson, Of Counsel 926 Chulie Drive San Antonio, Texas 78216 Telephone No. (210) 225-6666 Facsimile No. (210) 225-2300 carl@carlkolblaw.com conrydavidson@gmail.com /s/ Elizabeth Conry Davidson Carl J. Kolb Elizabeth Conry Davidson *4 ATTORNEYS FOR APPELLEE CERTIFICATE OF CONFERENCE I hereby certify that I have conferred with opposing counsel, Michael
J. Murray regarding the subject matter and substance of the foregoing
Motion and he has indicated that he does not oppose this Motion.
/s/Elizabeth Conry Davidson ELIZABETH CONRY DAVIDSON CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing
instrument was delivered to the following in accordance with the Texas
Rules of Civil and Appellate Procedure on this the 4th day of February,
2015:
Michael J. Murray
Watts Guerra, LLP
4 Dominion Drive
Building 3, Suite 100
San Antonio, Texas 78257
Michael Miller
Law Office of Michael Miller
926 Chulie Drive
San Antonio, Texas 78216
/s/ Elizabeth Conry Davidson CARL J. KOLB ELIZABETH CONRY DAVIDSON