Case Information
*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 9/21/2015 3:40:29 PM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-15-00392-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 9/21/2015 3:40:29 PM KEITH HOTTLE CLERK No. 04–15–00392–CV JOYCE ANN SARRO IN THE COURT OF APPEALS
vs. 4TH COURT OF APPEALS DISTRICT
MICHAEL A. SARRO SAN ANTONIO, TEXAS
Motion for Extension of Time To File a Brief by Appellant
(Unopposed)
Comes now appellant, Joyce Ann Sarro, and moves the Court to extend the time to
file her brief, pursuant to Tex. R. App. P. 10.1, 10.5, and Article I, section 19 of the Texas
Constitution.
1. Appellant’s brief is presently due on September 21, 2015.
2. An extension for 30 days is requested to October 21, 2015.
3. The undersigned counsel for Appellant has been responsible for the care of two
family members, one of whom passed away in June 2015. His brother, handicapped with
Down’s Syndrome, has additional difficulties including the necessity of being prompted
when eating. On August 31, 2015, the brother was hospitalized and was released on
September 5, 2015. A copy of the discharge document is attached as exhibit ’A’ and is
made a part of this motion. This new development has required additional attention.
4. This is the first request for an extension of time to file a brief by Appellant.
5. This extension is not sought solely for delay, but that justice may be done.
6. An inquiry was made about this motion to the attorney for Appellee, who indicated
that the motion is not opposed.
Prayer Therefore, Joyce Ann Sarro prays that this motion be filed, that an extension of time
be granted to October 21, 2015 to file Appellant’s brief, and that she have such other relief,
in law or equity, to which she may be justly entitled.
Respectfully submitted, /s/ R. Robert Willmann, Jr. R. Robert Willmann, Jr. Attorney at Law P.O. Box 460167 San Antonio, Texas 78246 Tel 844.244.9973 Temporary Fax 361.552.4305 willaw@prismnet.com Bar No. 21655960 Certificate of Service I certify that this motion was served by–
electronic service through an electronic filing manager and by fax to Rachel Sadovsky;
Cordell & Cordell; 10101 Reunion Place, Suite 250; San Antonio, Texas 78216
(rsadovsky@cordelllaw.com) (attorney for Michael A. Sarro);
on the 21st day of September, 2015.
/s/ R. Robert Willmann, Jr. R. Robert Willmann, Jr. *3 Exhibit A *4 Affidavit Regarding Exhibit State of Texas
County of Calho~~n
Before me, the undersigned authority, personally appeared R. Robert Wdlmam, Jr.,
who, after being duly sworn, stated as follows.
"I, R. Robert Willmann, Jr., am over 18 years of age, am an attorney licensed to practice law in the State of Texas, and am otherwise competent to make this affidavit.
:^.
I am an attorney for appellant Joyce Ann Sarro regarding this appeal.
Attached to this affidavit and made a part of this exhibit 'A' is a true and complete copy
of a discharge sheet for my brother David Wilhnann regarding his recent hospitalization,
with some redactions. I signed the paper at the hospital and received a copy there.
I have personal knowledge of the contents of this affidavit and they are true and
correct." d
R. Robert Willmann, Jr. Affiant Subscribed and sworn to before me on this 18th day of September, 2015, to which witness
my hand and seal of office.
A
NO& Public, State of Texas / My commission expires:
Discharge Instructions
Printed: 09/05/15 20:09 Page 2 of 2
L MEDICATIONS -
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Route: BY Fre enc DAILY Prescri 5io!%%ail: TAKE 250 MI%IG&S BY MOUTH DAILY ~nstructions TAKE 2 TABS ON IST DAY THEN 1 TABLET DAILY
Next Dose Due: 09/05/2015 12:OO PM
- Continue -"Route : OUTH Fre enc DAILY rescripti ion ~etai.1:;~~~ 500 MI%IG&S BY MOUTH DAILY Next Dose Due: TAKE AS DIRECTED / --
-1 P r e s c r i p t i o n 2 Route: ORAL Fre enc DAILY Next Dose Due: 09/05/2015 MILLLI%S 7:00 AM &L DAILY
7 ¥"'ESStg BY MOUTH g------ Frequency: EVERY EVENING Prescription Detail- TAKE 3 mill1 rams BY MOUTH EVERY EVENING Next Dose Due: 09/05/2015 5:00 ?M
PLEASE STOP TAKING ALL MEDICATIONS LISTED BELOW - - - - -
S h o p ~ h o u t e : BY MOUTH Frequency: DAILY
1 1 REFERRALS / TRANSITIONS OF CARE
Transition of Care
Provider : Phone : BETHANY HOME HEALTH
Address1 : Address2 : City: State: Zip: 00000 Reason for Transfer: Scheduled Date: Additional Information: (^(rfJt U L L u r s e p s signature: & , ^ / - Patient's signature: II
*- NUMBER: . -----', AGE: 59 PATIENT: WILLM SEX : ROOM: 105 PAG ANN DAVID NUMBER : --