Maribel Ambriz Martinez, Guadalupe Mota, Rosa Nelly Trevino v. Alfredo Gonzalez

• Court: Court of Appeals of Texas
• Decided: February 4, 2015
• Docket: 01-14-00552-CV
• Status: Published

Opinion

ACCEPTED 01-14-00552-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 2/4/2015 10:52:45 AM CHRISTOPHER PRINE CLERK

01-14-00552-CV FILED IN 1st COURT OF APPEALS In the First Court of Appeals HOUSTON, TEXAS

Houston, Texas 2/4/2015 10:52:45 AM CHRISTOPHER A. PRINE Clerk

MARIBEL AMBRIZ MARTINEZ, GUADALUPE MOTA, AND ROSA NELLY TREVINO, Appellants,

V.

ALFREDO GONZALEZ, Appellee.

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

CARL J. KOLB State Bar No. 11660480 carl@carlkolblaw.com CARL J. KOLB, P.C. 925 Chulie Drive San Antonio, Texas 78216 Telephone: (210) 225-6666 Facsimile: (210) 225-2300

ELIZABETH CONRY DAVIDSON Of Counsel State Bar No. 00793586 conrydavidson@gmail.com 925 Chulie Drive San Antonio, Texas 78216 Telephone: (210) 380-4899 Facsimile: (210) 225-2300

C o u n s e l f o r A p p e l l e e TO THE HONORABLE JUDGES OF THIS COURT:

Appellee, Alfredo Gonzalez respectfully presents this Second

Unopposed Motion for Extension of Time to file his Appellee’s Brief in this

matter, requesting that the time to file the Brief be extended by thirty days

from February 4, 2015 until March 6, 2015 as allowed by TEX. R. APP. P.

10.5(b) and 38.6. In support of this Motion, Appellee would show the Court

as follows:

The Appellants filed their Brief in this case on December 5, 2014,

making the Appellee’s Brief due on January 5, 2015, which was extended to

February 4, 2015. Due to the litigation, work and vacation schedule of

counsel for Appellee, a second thirty-day extension of time is sought to file

the Brief, up until March 6, 2015. This extension of time is not sought for

delay, but only so that justice may be done.

The numerous matters that the undersigned must attend to in their

law practices on a daily basis make it so that they will be unable to

complete the response requested in this case by the current due date.

Consequently, the Appellee respectfully requests an extension of time for

thirty (30) days, up through and including March 6, 2015.

2 This is the Appellee’s second request for an extension of time to file

the motion.

The undersigned counsel for Appellee has conferred with counsel for

the Appellant, Michael J. Murray, and he has indicated he is unopposed to

the extension.

Consequently, based on the foregoing, Appellee respectfully requests

an extension of time to file the Appellee’s Brief in this case for thirty days,

so that filing March 6, 2015 will be considered timely. This extension of

time is not sought for delay, but only so that justice may be done.

WHEREFORE, PREMISES CONSIDERED, Appellee prays that this

Court will grant the extension requested above.

Respectfully submitted,

CARL J. KOLB, P.C. Carl J. Kolb Conry Davidson, Of Counsel 926 Chulie Drive San Antonio, Texas 78216 Telephone No. (210) 225-6666 Facsimile No. (210) 225-2300 carl@carlkolblaw.com conrydavidson@gmail.com

/s/ Elizabeth Conry Davidson Carl J. Kolb State Bar No. 11660480 Elizabeth Conry Davidson

3 State Bar No. 00793586

ATTORNEYS FOR APPELLEE

CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with opposing counsel, Michael J. Murray regarding the subject matter and substance of the foregoing Motion and he has indicated that he does not oppose this Motion.

/s/Elizabeth Conry Davidson ELIZABETH CONRY DAVIDSON

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument was delivered to the following in accordance with the Texas Rules of Civil and Appellate Procedure on this the 4th day of February, 2015:

Michael J. Murray Watts Guerra, LLP 4 Dominion Drive Building 3, Suite 100 San Antonio, Texas 78257

Michael Miller Law Office of Michael Miller 926 Chulie Drive San Antonio, Texas 78216 /s/ Elizabeth Conry Davidson CARL J. KOLB ELIZABETH CONRY DAVIDSON