Case Information

*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 10/22/2015 10:58:11 PM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-14-00551-cv FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 10/22/2015 10:58:11 PM KEITH HOTTLE CLERK NO. 04-14-00551-CV IN THE COURT OF APPEALS FOR THE

FOURTH JUDICIAL DISTRICT OF TEXAS SAN ANTONIO, TEXAS PABLO SOLIZ § APPELLANT

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V. §

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STATE OF TEXAS § APPELLEE

APPEAL FROM 79 th JUDICIAL DISTRICT COURT BROOKS COUNTY, TEXAS TRIAL COURT NO. 14-02-16542-CV ________________________________________________________________

APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE

MOTION FOR RECONSIDERATION EN BANC Rick Soliz Attorney at Law Texas Bar Number 00785013 Houston, Texas 77210 713-228-1900 Counsel Pro Bono ________________________________________________________________

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes, Pablo Soliz , Appellant in the above entitled and numbered

cause, by and through his pro bono attorney of record, Rick Soliz, and submits

this first Motion for Extension of Time to file Appellant's Motion for

Reconsideration En Banc until November 5, 2015. For good cause, Appellant

shows as follows.

1. This Court issued its opinion on July 22, 2015. On September 8,

2015, Appellant’s motion for rehearing was filed and it was overruled on

September 22, 2015. This motion may be filed by October 22, 2015. This is

Appellant's first request for an extension of time to file Appellant's Motion for

Reconsideration En Banc.

2. In the last thirty days, Appellant's counsel has had a heavy

workload and out of town court business several times.

3. Furthermore, Appellant’s counsel, in the last 2 weeks, has attended

a continuing education seminar and concentrated on extensive State Bar of

Texas committee business. Counsel is also in the process of relocating his

primary office space to another location. The failure to file the motion for reconsideration en banc within the

specified period allowed was not deliberate or intentional. Appellant is

requesting an extension of time until November 5, 2015 and will not seek further

extensions. This Motion is not made for delay, but to see that justice is done.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the

deadline for filing of Appellant's motion for reconsideration en banc be extended

to November 5, 2015 or any date the court sees fit.

CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the attached and foregoing

document is served on opposing counsel.

Respectfully submitted, /S/

/s/ Rick Soliz T.B.N. 00785013 Houston, Texas 77210 713-228-1900 Pro Bono Attorney for Appellant