Worldwide Clinical Trials A/K/A Wct Corporation v. Herlinda Arnold

• Court: Court of Appeals of Texas
• Decided: December 29, 2014
• Docket: 14-0786
• Status: Published

Opinion

FILED 14-0786 12/24/2014 1:23:20 PM tex-3589887 SUPREME COURT OF TEXAS BLAKE A. HAWTHORNE, CLERK

CASE NO. 14–0786 _____________________________________________

IN THE SUPREME COURT OF TEXAS _____________________________________________

WORLDWIDE CLINICAL TRIALS, a/k/a WTC CORPORATION, Petitioner

V.

HERLINDA ARNOLD, Respondent _____________________________________________

On Petition for Review from the Fourth Court of Appeals, San Antonio, Texas, Case No. 04–13–00609–CV _____________________________________________

RESPONDENT’S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PETITIONER’S PETITION FOR REVIEW _____________________________________________

Respondent, Herlinda Arnold, requests a 30-day extension to file her response to

Petitioner’s Petition for Review and for good cause, would show as follows:

1. The Fourth Court of Appeals issued its opinion and judgment in the underlying

appeal, Case Number No. 04–13–00609–CV, on August 13, 2014.

2. After being granted three extensions of time, Petitioner filed its Petition for

Review with this Court on November 25, 2014.

3. Respondent’s response to Petitioner’s Petition for Review is December 24, 2014.

4. This is Respondent’s first request for an extension of time.

5. Respondent respectfully requests a 30–day extension to file its response so that

the undersigned attorneys can adequately prepare the response.

6. The undersigned attorneys have not had sufficient time to respond to Petitioner’s

Petition for Review due to the Thanksgiving holidays, taking time off for vacation and

hearings and obligations in other cases.

7. Pursuant to TEX. R. APP. P. 10.3, the undersigned attorneys conferred with

counsel for Petitioner, but have yet to receive a response from opposing counsel with

regard to whether he is opposed to this motion.

FOR THESE REASONS, Respondent prays that this Honorable Court grant this

Motion for Extension of Time to File Response to Petitioner’s Petition for Review and

extend the deadline for filing the response to January 26, 2014, and requests all other

relief to which she may be entitled.

Respectfully submitted,

Ecke and Poling, PLLC

By: ______/s/____________________ Joseph R. Ecke SBN: 24082946 1203 Buena Vista #201 San Antonio, Texas 78207 Email: joe.ecke@gmail.com Ph. (210) 645-5356 Fax (210) 775-6490

Law Office of Matthew S. Norris

By: ______/s/____________________ Matthew S. Norris

TBA No. 24076881 6243 IH-10 West, Suite 1010 San Antonio, Texas 78201 Email: mattnorrislaw@gmail.com Ph. (210) 549-7633 Fax (210) 446-4482

ATTORNEYS FOR RESPONDENT

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above has been served to all interested parties of record on this the 24th day of December 2014.

Sean Michael Reagan sreagan@lpmfirm.com 9545 Katy Freeway, Suite 200 Houston, Texas 77024

______/s/____________________ Joseph R. Ecke