Rita Gonzalez as Trustee of RG Family Trust and Ramon Gonzalez v. Don A. Janssen and Debra Janssen
Opinion
ACCEPTED
04-17-00347-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
9/27/2017 9:51 AM
NO. 04-17-00347-CV
IN THE COURT OF APPEALS
FOURTH DISTRICT OF TEXAS FILED IN 4th COURT OF APPEALS
SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 09/27/2017 9:51:15 AM
KEITH E. HOTTLE
CLERK
RITA GONZALEZ, as Trustee of the R.G. FAMILY IRREVOCABLE TRUST NO. 1, and RAMON GONZALEZ, JR.,
Appellants
v.
DON A. JANSSEN and DEBRA JANSSEN, Appellees
APPELLANTS’ UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE FOURTH COURT OF APPEALS:
Appellants Rita Gonzalez, as Trustee of the R.G. Family Irrevocable Trust No. 1 and Ramon Gonzalez, Jr. ask the Court to extend the time for filing their brief for 30 days to October 27, 2017, and in support of this motion shows:
Date of Judgment, Number and Style of Case 1. This is an appeal from the trial court’s Interlocutory Judgment signed on February 15, 2017, by the Honorable Russell Wilson, 81st Judicial District Court, Wilson County, Texas, in Cause 15-
09-00215-A-CVK, styled Rita Gonzalez, as Trustee of the R.G. Family Irrevocable Trust No.1, and Ramon Gonzalez, Jr. v. Don A. Janssen and wife, Debra Janssen, assigned to the 81st Judicial District Court, Wilson County, Texas.
Perfection of Appeal
2. Appellants filed their notice of appeal on May 30, 2017.
Record
3. The clerk’s record was filed on July 14, 2017 and the reporter’s record was filed on August 28, 2017.
Current Deadline
4. Appellants’ Brief is due on September 27, 2017.
Length of Extension
5. Appellants seek a 30-day extension of time to file their brief to October 27, 2017.
Need for Extension
6. The undersigned counsel has the primary responsibility for preparing the brief. During the last thirty (30) days, she has been involved in matters in other cases, which have hampered her ability to prepare this brief.
First Request for Extension 7. Appellants have neither requested nor received any previous extensions.
No Opposition
8. Appellants’ attorney has conferred with counsel for Appellees, who does not oppose this motion.
Prayer
9. For all these reasons, Appellants respectfully ask this Court to grant this motion and to extend the date for filing Appellants’ brief for a period of 30 days, to October 27, 2017.
Respectfully submitted,
/s/ Catherine M. Stone
CATHERINE M. STONE
State Bar No. 19286000
cstone@langleybanack.com
BRUCE K. SPINDLER
State Bar No. 18947050
bspindler@langleybanack.com ROBINSON C. RAMSEY
State Bar No. 16523700
rramsey@langleybanack.com LANGLEY & BANACK, INC.
Trinity Plaza II, Suite 700 745 E. Mulberry Avenue
San Antonio, Texas 78212
Telephone: 210.736.6600
Telecopier: 210.735.6889
ATTORNEYS FOR APPELLANTS
CERTIFICATE OF CONFERENCE
The undersigned counsel has conferred with counsel for Appellees who does not oppose this motion.
/s/ Catherine M. Stone
CATHERINE M. STONE
CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was served upon the following counsel of record on this 27th day of September, 2017:
David C. Griffin Email: dcg@lawmgk.com Michael Neuerburg Email: mnueburg@lawmgk.com MAREK, GRIFFIN & KNAUPP P.O. Box 2329 Victoria, Texas 77902-2329 Telephone: 361.573.5500 Telecopier: 361.573.5040
/s/ Catherine M. Stone
CATHERINE M. STONE
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Rita Gonzalez as Trustee of RG Family Trust and Ramon Gonzalez v. Don A. Janssen and Debra Janssen (Rita Gonzalez as Trustee of RG Family Trust and Ramon Gonzalez v. Don A. Janssen and Debra Janssen) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.