Joyce Ann Sarro v. Michael A. Sarro

Court of Appeals of Texas·Decided December 21, 2015·No. 04-15-00392-CV·Published

Opinion

ACCEPTED

04-15-00392-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS 12/21/2015 12:19:48 PM

KEITH HOTTLE

CLERK

NO. 04-15-00392—CV

IN THE FOURTH COURT OF APPEALS FILED IN

SAN ANTONIO, TEXAS 4th COURT OF APPEALS SAN ANTONIO, TEXAS 12/21/15 12:19:48 PM

KEITH E. HOTTLE

Clerk

JOYCE ANN SARRO,

Appellant,

V.

MICHAEL A. SARRO,

Appellee.

FIRST UNOPPOSED MOTION FOR EXTENSION OF TINIE TO FILE APPELLEE’S BRIEF

Rachel S. Sadovsky Cordell & Cordell, P.C. 1010] Reunion Place, Suite 250 San Antonio, Texas 78216 Tel: (210) 812-3400 Fax: (210)812-3401 rsadovsky@corde1llaw.com SBN: 24081315 Counsel for Appellee Michael A. Sarro

Cause No. 04-15-00392-CV SARRO V. SARRO Motionfor Extension of Time to File Brief — ad Page 1

TO THE HONORABLE FOURTH COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellee, Michael A.

Sarro, ﬁles this Unopposed First Motion to Extend Time to File Appel1ee’s Brief.

Appel1ee’s opening brief is currently due on December 21, 2015.

Counsel for Appellee requests a 30-day extension of time to ﬁle its brief,

making the brief due on January 20, 2016. This is the ﬁrst request for extension of

time to ﬁle the reply brief.

Counsel for Appellee relies on the following reasons, in addition to the

routine matters that counsel must attend to in daily practice, to explain the need for

the requested extension:

1. Counsel for Appellee has had a vacation planned since mid-year and

has had a vacation letter on ﬁle with the courts since November of this

year, attached hereto as Exhibit A; and

2. Counsel for Appellee has already provided counsel for Appellant two

extensions of time to file their brief and counsel for Appellant has

indicated that he would not oppose the extension.

Counsel for Appellee seeks this extension of time to be able to prepare a

cogent and succinct brief to aid this Court in its analysis of the issues presented.

Cause No. 04-15-00392—CV SARRO V SARRO Motion for Extension of Time to File Brief — ad Page 2

This request is not sought for delay but so that justice may be done.

The undersigned has conferred with opposing counsel, and he has indicated

that his client does not oppose this motion.

All facts recited in this motion are within the personal knowledge of the

counsel signing this motion, therefore no Verification is necessary under Rule of

Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellee requests that this Court grant this

Unopposed First Motion to Extend Time to File Appellee’s Brief and extend the

Deadline for Filing the Appellee’s Brief up to and including January 20, 2016.

Appellee prays for all other relief to which he may be entitled.

Respectfully submitted,

llama J M Rachel S. Sadovsky Cordell & Cordell, P.C. 10101 Reunion Place, Suite 250 San Antonio, Texas 78216 Tel: (210)812-3400 Fax: (210) 812-3401 rsadovsky@cordelllaw.com SBN: 24081315 Counsel for Appellee Michael A. Sarro

Cause No. 0445-00392-CV SARRO V. SARRO Motion for Extension of Time to File Brief — ad Page 3

CERTIFICATE OF CONFERENCE

I certify that I conferred with counsel for Appellant regarding this motion and that

Appellee/Appellant is not opposed to this motion.

Rachel S. Sadovsky K) Counsel for Appellee Michael A. Sarro

CERTIFICATE OF SERVICE

I certify that on December 21, 2015, I served this motion through electronic service

through an electronic ﬁling manager and by fax to R. Robert Willmann; Attorney

at Law; P.O. Box 460167, San Antonio, Texas 78246; (361) 552-4305

(willaw@prismnet.com) — Attorney for Appellant Joyce Ann Sarro.

Rachel S. Sadovsky U Counsel for Appellee Michael A. Sarro

Cause No. 04-15-00392-CV SARRO V SARRO Motion for Extension of Time to File Brief - ad Page 4 _'

FILED 3 11/23/2015 11:53:01 AM ;

Donna Kay McKinney Bexar County District Clerk

C Cordell Cordell

Accepted By: Cynthia Flores 1'

A Domestic Litigation Firm A Partner Men Can COUﬂi' OI’l.‘3

RACHEL S. SADOVSKY

ASSOCIATE ATTORNEY rsadovsky@cordelllaw.coin

November 17, 2015

Civil Jury Setting Clerk CivilNon—Ju1y Setting Clerk Bexar County Courthouse Bexar County Courthouse 100 Dolorosa Street 100 Dolorosa Street San Antonio, Texas 78205 San Antonio, Texas 78205

Bexar County District Clerk Guadalupe County District Clerk Paul Elizondo Tower Guadalupe County Courthouse 101 W. Nueva, Suite 217 101 E. Court St., Suite 308 San Antonio, Texas 78205 Seguin, Texas 78155

Bandera County District Clerk Wilson County District Clerk P. O. Box 2688 PO. Box 812 Bandera, Texas 78003 Floresville, Texas 78114

Kerr County District Clerk Kendall County District Clerk Kerr County Courthouse Kendall County Courthouse 700 Main Street 201 E. San Antonio Street, Ste. 201 Kerrville, Texas 78028 Boeme, Texas 78006

Karnes County District Clerk Uvalde County District Clerk 210 W. Calvert, Suite 180 Courthouse Plaza, Box 15 Kames City, Texas 78118 Uvalde, Texas 78801

Gillespie County District Clerk Atascosa County District Clerk 101 West Main Street, Atascosa County Courthouse Mail Unit 3, Room 204 1 Courthouse Circle Drive, Suite 4-B

Fredericksburg, Texas 78624-3700 Jourdanton, Texas 78026

Bee County District Clerk Medina County District Clerk P. O. Box 666 1100 16th Street, Room 209 Beeville, Texas 78104 Hondo, Texas 78861

Maverick County District Clerk Cameron County District Clerk 500 Quarry Street, Suite 5 Cameron County Courthouse Eagle Pass, Texas 78852 Judicial Building, 3rd Floor 974 East Harrison Street Brownsville, Texas 78520

Phone: 210.812.3400 10101 Reunion Place MansDivon:e.com -

I3adsDivovce.com - Cordeilcordeiimom Fax‘ 210.812.3401 Suite 250 Cordell & Cordell, RC.

(

Cordell Law. LLP

Toll Free: 866,323.7529 San Antonio, TX 78216

Re: Vacation Notice

Dear Sir and/or Madarns:

This serve as notice that I will be out of the office on vacation, letter shall

ﬁrm business

or involved in State Bar related activities during the following periods:

December 21, 2015 to December 30, 2015

I would appreciate your assistance in not scheduling any court settings, trials, or otherwise for me during this time period.

Thank you for your cooperation and professional courtesies.

Best regards, CORDELL & CoRDELL,,P.C.

, >4 ~~

RACHEL s. SADOVSKY Texas State Bar No. 240813

RSS:jh

co: Opposing Counsel via facsimile

MensDivorce.com -

DadsDivorce.com - CordellCordeI|.corn Cordell & Cordell, PC|

Cordell Law. LLP

Free access — add to your briefcase to read the full text and ask questions with AI

ACCEPTED

04-15-00392-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS 12/21/2015 12:19:48 PM

KEITH HOTTLE

CLERK

NO. 04-15-00392—CV

IN THE FOURTH COURT OF APPEALS FILED IN

SAN ANTONIO, TEXAS 4th COURT OF APPEALS SAN ANTONIO, TEXAS 12/21/15 12:19:48 PM

KEITH E. HOTTLE

Clerk

JOYCE ANN SARRO,

Appellant,

V.

MICHAEL A. SARRO,

Appellee.

FIRST UNOPPOSED MOTION FOR EXTENSION OF TINIE TO FILE APPELLEE’S BRIEF

Cause No. 04-15-00392-CV SARRO V. SARRO Motionfor Extension of Time to File Brief — ad Page 1

TO THE HONORABLE FOURTH COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellee, Michael A.

Sarro, ﬁles this Unopposed First Motion to Extend Time to File Appel1ee’s Brief.

Appel1ee’s opening brief is currently due on December 21, 2015.

Counsel for Appellee requests a 30-day extension of time to ﬁle its brief,

making the brief due on January 20, 2016. This is the ﬁrst request for extension of

time to ﬁle the reply brief.

Counsel for Appellee relies on the following reasons, in addition to the

routine matters that counsel must attend to in daily practice, to explain the need for

the requested extension:

1. Counsel for Appellee has had a vacation planned since mid-year and

has had a vacation letter on ﬁle with the courts since November of this

year, attached hereto as Exhibit A; and

2. Counsel for Appellee has already provided counsel for Appellant two

extensions of time to file their brief and counsel for Appellant has

indicated that he would not oppose the extension.

Counsel for Appellee seeks this extension of time to be able to prepare a

cogent and succinct brief to aid this Court in its analysis of the issues presented.

Cause No. 04-15-00392—CV SARRO V SARRO Motion for Extension of Time to File Brief — ad Page 2

This request is not sought for delay but so that justice may be done.

The undersigned has conferred with opposing counsel, and he has indicated

that his client does not oppose this motion.

All facts recited in this motion are within the personal knowledge of the

counsel signing this motion, therefore no Verification is necessary under Rule of

Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellee requests that this Court grant this

Unopposed First Motion to Extend Time to File Appellee’s Brief and extend the

Deadline for Filing the Appellee’s Brief up to and including January 20, 2016.

Appellee prays for all other relief to which he may be entitled.

Respectfully submitted,

llama J M Rachel S. Sadovsky Cordell & Cordell, P.C. 10101 Reunion Place, Suite 250 San Antonio, Texas 78216 Tel: (210)812-3400 Fax: (210) 812-3401 rsadovsky@cordelllaw.com SBN: 24081315 Counsel for Appellee Michael A. Sarro

Cause No. 0445-00392-CV SARRO V. SARRO Motion for Extension of Time to File Brief — ad Page 3

CERTIFICATE OF CONFERENCE

I certify that I conferred with counsel for Appellant regarding this motion and that

Appellee/Appellant is not opposed to this motion.

Rachel S. Sadovsky K) Counsel for Appellee Michael A. Sarro

CERTIFICATE OF SERVICE

I certify that on December 21, 2015, I served this motion through electronic service

through an electronic ﬁling manager and by fax to R. Robert Willmann; Attorney

at Law; P.O. Box 460167, San Antonio, Texas 78246; (361) 552-4305

(willaw@prismnet.com) — Attorney for Appellant Joyce Ann Sarro.

Rachel S. Sadovsky U Counsel for Appellee Michael A. Sarro

Cause No. 04-15-00392-CV SARRO V SARRO Motion for Extension of Time to File Brief - ad Page 4 _'

FILED 3 11/23/2015 11:53:01 AM ;

Donna Kay McKinney Bexar County District Clerk

C Cordell Cordell

Accepted By: Cynthia Flores 1'

A Domestic Litigation Firm A Partner Men Can COUﬂi' OI’l.‘3

RACHEL S. SADOVSKY

ASSOCIATE ATTORNEY rsadovsky@cordelllaw.coin

November 17, 2015

Civil Jury Setting Clerk CivilNon—Ju1y Setting Clerk Bexar County Courthouse Bexar County Courthouse 100 Dolorosa Street 100 Dolorosa Street San Antonio, Texas 78205 San Antonio, Texas 78205

Bexar County District Clerk Guadalupe County District Clerk Paul Elizondo Tower Guadalupe County Courthouse 101 W. Nueva, Suite 217 101 E. Court St., Suite 308 San Antonio, Texas 78205 Seguin, Texas 78155

Bandera County District Clerk Wilson County District Clerk P. O. Box 2688 PO. Box 812 Bandera, Texas 78003 Floresville, Texas 78114

Kerr County District Clerk Kendall County District Clerk Kerr County Courthouse Kendall County Courthouse 700 Main Street 201 E. San Antonio Street, Ste. 201 Kerrville, Texas 78028 Boeme, Texas 78006

Karnes County District Clerk Uvalde County District Clerk 210 W. Calvert, Suite 180 Courthouse Plaza, Box 15 Kames City, Texas 78118 Uvalde, Texas 78801

Gillespie County District Clerk Atascosa County District Clerk 101 West Main Street, Atascosa County Courthouse Mail Unit 3, Room 204 1 Courthouse Circle Drive, Suite 4-B

Fredericksburg, Texas 78624-3700 Jourdanton, Texas 78026

Bee County District Clerk Medina County District Clerk P. O. Box 666 1100 16th Street, Room 209 Beeville, Texas 78104 Hondo, Texas 78861

Phone: 210.812.3400 10101 Reunion Place MansDivon:e.com -

I3adsDivovce.com - Cordeilcordeiimom Fax‘ 210.812.3401 Suite 250 Cordell & Cordell, RC.

(

Cordell Law. LLP

Toll Free: 866,323.7529 San Antonio, TX 78216

Re: Vacation Notice

Dear Sir and/or Madarns:

This serve as notice that I will be out of the office on vacation, letter shall

ﬁrm business

or involved in State Bar related activities during the following periods:

December 21, 2015 to December 30, 2015

I would appreciate your assistance in not scheduling any court settings, trials, or otherwise for me during this time period.

Thank you for your cooperation and professional courtesies.

Best regards, CORDELL & CoRDELL,,P.C.

, >4 ~~

RACHEL s. SADOVSKY Texas State Bar No. 240813

RSS:jh

co: Opposing Counsel via facsimile

MensDivorce.com -

DadsDivorce.com - CordellCordeI|.corn Cordell & Cordell, PC|

Cordell Law. LLP

Joyce Ann Sarro v. Michael A. Sarro, (Tex. Ct. App. 2015).

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