United Parcel Service, Inc. and Roland Leal v. Robert Scott Rankin, Individually, Rachelle Rankin, Individually and as Next Friend for Avery Rankin, Kara Rankin, and Samuel Rankin, Minors

• Court: Court of Appeals of Texas
• Decided: January 15, 2015
• Docket: 04-14-00494-CV
• Status: Published

Opinion

ACCEPTED 04-014-00494-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 1/15/2015 9:45:06 AM KEITH HOTTLE CLERK

NO. 04-014-00494-CV

FILED IN 4th COURT OF APPEALS IN THE FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 01/15/2015 9:45:06 AM KEITH E. HOTTLE Clerk

UNITED PARCEL SERVICE, INC. and ROLAND LEAL

Appellants/Cross-Appellees

v.

ROBERT SCOTT RANKIN, Individually; RACHELLE RANKIN, Individually and as Next Friend for AVERY RANKIN, a Minor; as Next Friend for KARA RANKIN, a Minor; and as Next Friend for SAMUEL RANKIN, a Minor

Appellees/Cross-Appellants

On Appeal from the 224th Judicial District Court, Bexar County, Texas Honorable Cathy Stryker, Presiding Judge Trial Court Cause No. 2011-CI-07922

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Appellees, Robert Scott Rankin, Rachelle Rankin, Avery Rankin, Kara Rankin,

and Samuel Rankin, by and through their undersigned attorneys, hereby move the

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 1 of 4 Court for an Order extending the time to file Appellees’ Response Brief, and as

grounds therefor would show the Court the following:

1. Appellees’ Response Brief is due on or before January 20, 2015.

2. Appellees respectfully request that the Court extend their current briefing

deadline of January 20, 2015, to and including January 30, 2015. No previous

extension of time has been granted for the filing of Appellees’ Response Brief.

3. Undersigned counsel has had an unusually busy schedule in December and

January, primarily due to the holiday season and the work required to prepare for

vacation time around the holiday season. Given that, undersigned counsel has not

had, and will not have, an opportunity to properly prepare the brief on the issues in

this matter by the current deadline.

WHEREFORE, Appellees pray that the time for filing their response brief be

extended to and including January 30, 2015; and for such other and further relief as

the Court may deem to be just and proper.

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 2 of 4 Respectfully submitted,

THE PERRIN LAW FIRM 1910 Pacific Avenue, Suite 6050 Dallas, Texas 75201 Telephone: (214) 646-2004 Facsimile: (214) 646-6117 Email: dougperrin@perrinlaw.org markperrin@perrinlaw.org

/s/J. Mark Perrin Doug Perrin State Bar No. 15796520 J. Mark Perrin State Bar No. 24013313

REESE GORDON MARKETOS LLP 750 N. St. Paul Street, Suite 610 Dallas, Texas 75201 Telephone: (214) 382-9810 Facsimile: (214) 501-0731 Email: pete.marketos@rgmfirm.com Pete Marketos State Bar No. 24013101

KEELING & DOWNES, P.C. 1500 McGowen Street Houston, Texas 77004 Telephone: (832) 214-9900 Fax: (832) 214-9908 Email: bck@keelingdownes.com Byron Keeling State Bar No. 11157980

ATTORNEYS FOR CROSS-APPELLANTS

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 3 of 4 CERTIFICATE OF CONFERENCE

I have conferred with counsel for Appellants/Cross-Appellees about the merits of this Motion and was advised that Appellants/Cross-Appellees do not oppose the relief requested in this Motion.

Certified this 15th day of January, 2015.

/s/J. Mark Perrin J. Mark Perrin

CERTIFICATE OF SERVICE

This will certify that a true and correct copy of the above and foregoing document was forwarded to all counsel of record in the above cause through the Court’s electronic case filing system, on this the 15th day of January, 2015.

Ricardo Reyna Audrey Haake Brock, Person, Guerra, Reyna P.C. 17339 Redland Road San Antonio, Texas 78247

W. Randall Bassett Bradley Pratt King & Spalding, LLP 1180 Peachtree Street, NE Atlanta, Georgia 30309

H. Victor Thomas King & Spalding, LLP 1100 Louisiana, Suite 4000 Houston, Texas 77002

/s/J. Mark Perrin

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 4 of 4