Case Information

*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 4/13/2015 3:16:10 PM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-14-00564-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 4/13/2015 3:16:10 PM KEITH HOTTLE CLERK NO. 04-14-00564-CV IN THE COURT OF APPEALS FOURTH DISTRICT OF TEXAS SAN ANTONIO, TEXAS IN THE ESTATE OF WADE R. BEDELL, JR. DECEASED APPELLEE’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE FOURTH COURT OF APPEALS:

Appellee Robyn Joan Zalewa asks the Court to extend the time for

filing her brief to and including April 23, 2015, and in support of this

motion shows:

Date of Judgment, Number and Style of Case This is an appeal from a final judgment signed on April 1, 2014, by the Honorable Tom Rickhoff, Probate Court No. 2, Bexar County, Texas,

in Cause No. 2013-PC-0636, styled In the Estate of Wade R. Bedell, Jr.,

Deceased .

Perfection of Appeal 2. Appellant Deborah Bedell filed her notice of appeal with this

Court on August 7, 2014. *2 Record

3. The clerk’s record was filed with this Court on August 7, 2014,

with subsequent supplemental clerk’s records that were filed on August 27,

2014, September 9, 2014, October 9, 2014, December 31, 2014, and January

12, 2015. The reporter’s record was filed with this Court on August 14,

2014, and a supplemental reporter’s record filed on February 18, 2015.

Current Deadline 4. Appellant filed her amended brief on February 10, 2015. After

having received one previous extension, Appellee’s brief is due on April 13,

Length of Extension Sought 5. Appellant requests a 10-day extension to April 23, 2015.

Facts Reasonably Explaining Need for Extension During the last thirty (30) days, the undersigned attorney who has the

primary responsibility to prepare Appellee’s Brief, has been involved in the

following matters, which have hampered his ability to prepare Appellant’s

Brief, as follows:

• Preparation of appellant’s reply brief in Cause No. 04-14-00903-CV,

Lightning Oil Company v. Anadarko E&P Onshore LLC fka

Anadarko E&P Company ; Fourth Court of Appeals, San Antonio,

Texas;

• Preparation of response to petition for writ of mandamus in Cause

No. 15-0109; In re Gilbert L. Mathews and Lucifer Lighting

Company ; Supreme Court of Texas, Austin, Texas; *3 • Preparation of post-trial motions and briefs in Cause No. 29842;

Knighthawk, LLC, Series G v. B&P Development and Chad H. Foster,

Jr ., 83 rd Judicial District Court, Val Verde County, Texas; and

• Preparation of petitioner’s brief on the merits in Cause No. 14-0223;

Methodist Healthcare System of San Antonio, LTd., LLP dba

Northeast Methodist Hospital v. Thomas Dewey ; Supreme Court of

Texas, Austin, Texas.

Second Request for Extension 6. This is the second request for an extension of time to file

Appellee’s brief.

Request for Relief For all these reasons, Appellee Robyn Joan Zalewa respectfully asks this Court to grant this motion and to extend the date for filing her

brief for a period of 10 days, to April 23, 2015.

Respectfully submitted, /s/ Robinson C. Ramsey ROBINSON C. RAMSEY State Bar No. 16523700 Email: rramsey@langleybanack.com JAMES W. CARTER, IV State Bar No. 24006333 Email: jcarter@langleybanack.com LANGLEY & BANACK, INC. Trinity Plaza II, Suite 900 745 E. Mulberry Avenue San Antonio, Texas 78212 Telephone: 210. 736.6600 Telecopier: 210. 735.6889 ATTORNEYS FOR APPELLEE ROBYN ZALEWA *4 CERTIFICATE OF CONFERENCE Appellee’s attorney has conferred with Appellant’s counsel, John

Wennermark, who does not oppose this motion.

/s/Robinson C. Ramsey ROBINSON C. RAMSEY CERTIFICATE OF SERVICE A true and correct copy of the foregoing document was served upon

the following counsel for Appellant:

John D. Wennermark

State Bar No. 21177000

Email: johnwennermark@hotmail.com

1924 N. Main Avenue

San Antonio, Texas 78212

Telephone: 210.226.6262

Telecopier: 210.225.1351

on this 13 th day of April, 2015.

/s/ Robinson C. Ramsey ROBINSON C. RAMSEY