John A. Lance, Debra L. Lance, F.D. Franks and Helen Franks v. Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray and Butch Townsend

Court of Appeals of Texas·Decided June 3, 2015·No. 04-14-00758-CV·Published

Opinion

ACCEPTED 04-14-00758-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 6/3/2015 3:41:37 PM KEITH HOTTLE CLERK

NO. 04-14-00758-CV FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 6/3/2015 3:41:37 PM In The KEITH E. HOTTLE Clerk

Fourth Court of Appeals San Antonio, Texas

John A. Lance, Debra L. Lance, F. D. Franks and Helen Franks, Appellants v.

Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray, Butch Townsend, and Bexar-Medina-Atascosa Counties Water Control and Improvement District No. 1, Appellees

SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEE'S BRIEF (UNOPPOSED)

\Vater Control

District No. 1 (BMA) file their second for extension of time to file

s Appellee's IS on June 8, 2015. R. P.

38.6. This motion is filed prior to the due date. Appellant's counsel does not

oppose this motion.

Appellee needs additional time to prepare and file their brief. Appellee asks

the Court to grant an extension of time to Wednesday, July 8, 2015, an extension

of30 days.

Appellee's counsel was preparing for and arguing a Motion for Summary

Judgment held on May 13, 2015, in the matter of WPS, LLC A Texas Limited

Liability Company D/B/A Federal Management Solutions v. Mission Valley Mill

Holding, LLC, Cause No. 2013CVA0461, County Court at Law, Comal County,

Texas. Additionally, Appellee's counsel will be preparing for mediation tentatively

set on June 8, 2015, regarding the same matter.

Furthermore, Appellee's counsel sustained a back injury on May 25, 2015,

and a subsequent aggravation on May 27, 2015, which caused Appellee's counsel

to miss virtually the entire week of work May 25,2015 through May 29, 2015.

PRAYER

the

or

PRespectfully submitted,

GOSTOMSKI & HECKER, P.C. 607 Urban Loop San Antonio, Texas 78204-3117 (21 0) 222-9529 Telephone (210) 222-9540 Facsimile ed@ghlawyers.net

BY:

EDWARD T. HECKER State Bar No. 00787668 PETER B. GOSTOMSKI State Bar No. 00787571

ATTORNEYS FOR BMA

CERTIFICATE OF SERVICE

I certify that on June 2015, a true and correct copy of this document was served on the following counsel of record:

Dan Pozza VIA EMAIL: danpozza@yahoo.com Law Office of Dan Pozza 239 E. Commerce Street San Antonio, TX 78205 (21 0) 226-8888 Telephone (210) 224-6373 Facsimile

Stephen B. Rogers VIA EMAIL: steve@Togersmoorelaw.com ROGERS & MOORE PLLC

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John A. Lance, Debra L. Lance, F.D. Franks and Helen Franks v. Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray and Butch Townsend, (Tex. Ct. App. 2015).

John A. Lance, Debra L. Lance, F.D. Franks and Helen Franks v. Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray and Butch Townsend (John A. Lance, Debra L. Lance, F.D. Franks and Helen Franks v. Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray and Butch Townsend) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.