in the Estate of William Thomas Booth

Opinion

ACCEPTED 04-14-00897-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 12/7/2015 8:06:20 AM KEITH HOTTLE CLERK

NO. 04-14-00897-CV

FILED IN 4th COURT OF APPEALS IN THE COURT OF APPEALS SAN ANTONIO, TEXAS FOURTH COURT OF APPEALS DISTRICT OF TEXAS 12/7/2015 8:06:20 AM SAN ANTONIO, TEXAS KEITH E. HOTTLE Clerk

IN THE ESTATE OF WILLIAM T. BOOTH

APPELLEE’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUSTICES OF THE COURT:

ESTATE OF WILLIAM T. BOOTH, Appellee, submits its Second

Unopposed Motion for Extension of Time to File Appellee’s Brief and in support

of this motion states as follows:

1. Appellee’s Brief is due December 9, 2015.

2. This motion is filed prior to the expiration of this due date.

3. The undersigned has conferred with the attorney for Appellant and

this motion is unopposed.

4. Appellee requests an additional twenty (20) days to file its Appellee’s

Brief, extending the time to December 29, 2015.

5. One extension has previously been granted. 6. The undersigned is responsible for the preparation of this Appellee’s

Brief. The undersigned has been engaged in the formation of Pozza & Whyte,

PLLC, a partnership with attorney Lorien Whyte. The formation of this new firm

has taken considerable time during the relevant time period. The undersigned has

continued to be engaged in conducting numerous previously scheduled mediations,

including mediations related to the wrongful death and injury claims arising out of

the fire at the Wedgwood apartments. The undersigned has continued to be

engaged in providing litigation support in numerous cases for a number of trial

attorneys. This extension request is not filed for purposes of delay.

PRAYER

Appellee asks this Court to grant its motion extending the deadline to file its

Appellee’s Brief to December 29, 2015.

Respectfully submitted,

POZZA & WHYTE, PLLC 239 E. Commerce Street San Antonio, TX 78205 (210) 226-8888 – Phone (210) 222-8477 – Fax danpozza@pozzaandwhyte.com

/s/Dan Pozza State Bar No. 16224800

ATTORNEY FOR APPELLEE

2 CERTIFICATE OF SERVICE

I hereby that a true and correct copy of the above and foregoing document has been delivered via e-mail transmission on this 7th day of December, 2015, to:

Adan A. Gonzalez, III The Law Office of Donato D. Ramos, PLLC 6219 McPherson Road, Suite 35 Laredo, TX 78041 agonzalez@ddrlex.com

James K. Jones, Jr. The Law Office of James K. Jones, Jr. P.O. Box 560 Laredo, TX 78042 jkjjr@icloud.com

/s/Dan Pozza