Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. De C v. v. Free and Sovereign State of Chihuahua

Court of Appeals of Texas·Decided October 28, 2021·No. 08-21-00135-CV·Published

Opinion

ACCEPTED

08-21-00135-CV

EIGHTH COURT OF APPEALS

EL PASO, TEXAS

08-21-00135-CV 10/28/2021 1:03 PM ELIZABETH G. FLORES

CLERK

IN THE COURT OF APPEALS

FOR THE EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS FILED IN 8th COURT OF APPEALS

EL PASO, TEXAS

OSVALDO RODRIGUEZ BORUNDA § 10/28/2021 1:03:50 PM AND EDITORA PASO DEL NORTE, § ELIZABETH G. FLORES S.A. DE C.V., § Clerk §

Appellants, § §

v. § No. 08-21-00135-CV §

FREE AND SOVEREIGN STATE OF § CHIHUAHUA, § §

Appellee. §

APPELLANTS’ FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

TO THE HONORABLE COURT OF APPEALS:

COMES NOW Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. de C.V., Appellants, and files this, their First Unopposed Motion for an Extension of Time to File Appellants’ Reply Brief, and in support thereof, would respectfully show as follows:

1. Appellants filed their Brief on September 2, 2021.

2. Appellee’s Response Brief was due on September 30, 2021. Appellee was granted an extension until October 13, 2021 to file his Brief.

3. Appellee filed his Response Brief on October 14, 2021.

4. Appellants’ Reply Brief is due to be filed November 3, 2021.

5. Appellants request an extension of time to November 15, 2021 to file their Reply Brief.

6. This extension is requested because Appellants’ attorney will be unable to complete the Reply Brief by the due date because of counsel’s responsibilities on other urgent client matters.

7. This is Appellants’ first motion for an extension of time to file Appellants’ Reply Brief. This request is not made for purposes of delay, but so that justice may be done. Appellee has consented to this request.

8. For these reasons, Appellants, requests an extension of time to November 15, 2021 to file Appellants’ Reply Brief, and such other and further relief to which they may be justly entitled.

Respectfully submitted,

GORDON DAVIS JOHNSON & SHANE P.C.

4695 N. Mesa Street

El Paso, Texas 79912

(915) 545-1133

(915) 545-4433 (Fax)

hdavis@eplawyers.com

By: /s/ Harrel L. Davis Harrel L. Davis III

State Bar No. 05567560

Attorney for Appellants

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was filed with the Court via the EFile.TXCourts.gov system on October 28, 2021. All attorneys identified with the Court for electronic service on record in this case were served by electronic service in accordance with the EFile.TXCourts.gov system.

/s/ Harrel L. Davis

Harrel L. Davis III

CERTIFICATE OF CONFERENCE

The undersigned attorney has conferred with counsel for Appellee who stated he does not oppose this motion.

/s/ Harrel L. Davis

Harrel L. Davis III

Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Virginia Rust on behalf of Harrel Davis III Bar No. 5567560 vrust@eplawyers.com Envelope ID: 58633589 Status as of 10/28/2021 2:34 PM MST

Associated Case Party: Editora Paso Del Norte, S.A. de C.V. Name BarNumber Email TimestampSubmitted Status Harrel LDavis III hdavis@eplawyers.com 10/28/2021 1:03:50 PM SENT Virginia Rust vrust@eplawyers.com 10/28/2021 1:03:50 PM SENT Cynthia Canales ccanales@eplawyers.com 10/28/2021 1:03:50 PM SENT Victoria Pena vpena@eplawyers.com 10/28/2021 1:03:50 PM SENT

Associated Case Party: Free and Sovereign State of Chihuahua Name BarNumber Email TimestampSubmitted Status Jessica Salto jsalto@txattorneys.com 10/28/2021 1:03:50 PM SENT Caroline Adams cadams@txattorneys.com 10/28/2021 1:03:50 PM SENT Christopher Leavitt cleavitt@txattorneys.com 10/28/2021 1:03:50 PM SENT Anthony Buzbee tbuzbee@txattorneys.com 10/28/2021 1:03:50 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status R. Yetter pyetter@yettercoleman.com 10/28/2021 1:03:50 PM SENT Matthew Zorn mzorn@yettercoleman.com 10/28/2021 1:03:50 PM SENT Lisa Prince lprince@yettercoleman.com 10/28/2021 1:03:50 PM SENT Bryce Callahan bcallahan@yettercoleman.com 10/28/2021 1:03:50 PM SENT Victor Firth vfirth@f-jlaw.com 10/28/2021 1:03:50 PM SENT

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Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. De C v. v. Free and Sovereign State of Chihuahua, (Tex. Ct. App. 2021).

Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. De C v. v. Free and Sovereign State of Chihuahua (Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. De C v. v. Free and Sovereign State of Chihuahua) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.