Rita Gonzalez as Trustee of RG Family Trust and Ramon Gonzalez v. Don A. Janssen and Debra Janssen

• Court: Court of Appeals of Texas
• Decided: September 27, 2017
• Docket: 04-17-00347-CV
• Status: Published

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.

2 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 3 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