in the Estate of Consuella Perkins Ulbrich

Opinion

ACCEPTED 04-14-00812-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 3/11/2015 3:16:07 PM KEITH HOTTLE CLERK

Appeal No. 04-14-00812-CV

FILED IN IN THE COURT OF APPEALS 4th COURT OF APPEALS FOR SAN ANTONIO, TEXAS 03/11/2015 3:16:07 PM THE FOURTH SUPREME JUDICIAL DISTRICT SAN ANTONIO, TEXAS KEITH E. HOTTLE Clerk

IN THE ESTATE OF CONSUELLA PERKINS ULBRICH, DECEASED, DOUGLAS J. ULBRICH

Appellant

v.

ROBERT HOPE, DARLENE WILSON and DEBRA BYRD

Appellees

From the Probate Court No. 1, Bexar County, Texas Honorable Pooly Jackson Spencer, Presiding ____________________________________________________________

APPELLEES’ MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Appellees, Robert Hope, Darlene Wilson and Debra

Byrd(hereinafter “Appellees”), file this their Motion for

Extension of Time to File Appellees’ Opening Brief in the

above-referenced cause pursuant to Texas Rules of Appellate

Motion for Extension of Time to File Appellees’ Brief Page 1 Procedure 38.6(d) and 10.5(b), and in support thereof, would

show this Honorable Court as follows:

1. Pursuant to Texas Rule of Appellate Procedure

38.6(b), Appellees’ deadline to file their Appellees’ Opening

Brief is today, Wednesday, March 11, 2015.

2. This is Appellees’ first request for extension of

time to file their Appellees’ Opening Brief.

3. Appellees respectfully request an approximately

thirty (30) day extension to file their Appellees’ Opening

Brief - until Friday, April 10, 2015.

4. Appellees request this extension because the

undersigned has had insufficient time to adequately prepare a

cogent and succinct response to Appellant’s Opening Brief.

5. Appellees request this extension not for purposes of

delaying this appeal, but so that justice may be done.

Respectfully submitted,

Arlitt Law Firm, LLC

By: /s/ Kristine Arlitt KRISTINE ARLITT, ESQ. Texas Bar No. 24034117 206 Locust Street San Antonio Texas 78209 Telephone 210.821.6101 Telecopier 210.821.6105

Motion for Extension of Time to File Appellees’ Brief Page 2 Attorney for Appellees

Of Counsel:

Crist Law Firm, PLLC

By: /s/ William D. Crist WILLIAM D. CRIST, ESQ. Texas Bar No. 24043614 3123 N.W. Loop 410 San Antonio Texas 78230 Telephone 210.340.3277 Telecopier 210.372.0400

Attorney for Appellees

Motion for Extension of Time to File Appellees’ Brief Page 3 CERTIFICATE OF CONFERENCE

I received an email today, March 11, 2015, from opposing

counsel, Philip M. Ross stating he is opposed to the thirty

day extension.

/s/ William D. Crist William D. Crist

CERTIFICATE OF SERVICE

I certify that on the 11th day of March, 2015, a true copy

of this Motion for Extension of Time to File Appellees’ Brief

was served on the following:

Philip M. Ross Attorney for Appellant 1006 Holbrook Road San Antonio, Texas 78218

Via Facsimile to 210.590.2509

Motion for Extension of Time to File Appellees’ Brief Page 4