in the Interest of C.J.T., a Child

Opinion

ACCEPTED 04-14-00621-cv FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 7/14/2015 11:16:30 AM KEITH HOTTLE CLERK

CAUSE NO. 04-14-00621-CV

IN THE INTEREST OF § IN THE 49TH JUDICIAL FILED IN § 4th COURT OF APPEALS CARLOS JAVIER TOVAR, § DISTRICT COURT OFSAN ANTONIO, TEXAS § 07/14/2015 11:16:30 AM A CHILD § ZAPATA COUNTY, TEXAS KEITH E. HOTTLE Clerk APPELLEE’S THIRD MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

Appellee’s FRANCISCO TOVAR GUAJARDO, JR. files this motion for extension of

time and requires an additional thirty days to file his Appellee’s brief, extending the briefing

deadline to August 17, 2015. This is Appellee’s Third and last request for an extension on this

deadline. This extension is not sought for delay.

Appellee’s has been unable to finalize his brief due to his counsel working extensively

Appellee’s brief in another case filed also with this court. In addition Appellee’s counsel has had

numerous court settings on other contested matters in and out of her primary county of practice.

Then moreover, Appellee’s counsel is a sole practitioner with an extensive case load and require

additional time to complete the brief in this case. These obligations have hindered the undersigned

counsel’s ability to complete the brief for this cause by the July 17, 2015 deadline.

Prayer

Appellee’s FRANCISCO TOVAR GUAJARDO, JR. prays that his briefing deadline be extended to August 17, 2015. Respectfully Submitted,

/S/FLOR E. FLORES Flor E. Flores State Bar No. 24065235 THE LAW FIRM OF FLOR E. FLORES, PLLC 700 N. Flores St., Ste. E Rio Grande City, Texas 78582 Tel: (956)263-1786 Fax: (956)263-1750

1 ffloreslaw@gmail.com Attorney for Appellees Francisco Tovar CERTIFICATE OF SERVICE

I hereby certify that on July 14, 2015, a true and correct copy of this document was served

upon counsel for Appellees via electronic service.

Leticia Garcia Leticia.garcia.atty@gmail.com Counsel for Irma I. Perez-Chapa

Ricardo Pumarejo Jr. rpumarejo@ktattorneys.com Counsel for Maria Del Socorro Gonzalez and Cesario Gonzalez

/S/FLOR E. FLORES Flor E. Flores