James Clinton Coyle v. Coyle Family Farm, Inc.

ACCEPTED 04-16-00133-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 6/6/2016 3:51:47 PM KEITH HOTTLE CLERK IN THE COURT OF APPEALS FOR THE FOURTH APPELLATE DISTRICT OF TEXAS SAN ANTONIO, TEXAS FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS JAMES CLINTON COYLE, § 06/6/2016 3:51:47 PM Appellant, § KEITH E. HOTTLE § Clerk VS. § NO. 04-16-00133-CV § COYLE FAMILY FARM, INC., § Appellee. § ON APPEAL FROM CAUSE NO. 3208 COUNTY COURT AT LAW, MEDINA COUNTY, TEXAS HONORABLE VIVIAN TORRES, JUDGE PRESIDING APPELLANT’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE FOURTH COURT OF APPEALS: Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant, James Clinton Coyle (“Appellant”) files this Unopposed First Motion for Extension of Time to File Appellant’s Brief. Appellant’s brief is currently due on June 9, 2016. Counsel for Appellant requests a 60-day extension of time to file the opening brief. Counsel for Appellant relies on the following reasons, in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the requested extension:  Counsel for Appellant has a pre-planned vacation scheduled for the month of June. Counsel for Appellant seeks this extension of time to be able to prepare an effective and concise brief to aid this Court in its analysis of the issues presented. This request is not sought for delay but so that justice may be done. The undersigned counsel has conferred with opposing counsel and he has indicated that his client does not oppose this motion. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Texas Rule of Appellate Procedure 10.2. PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Unopposed First Motion for Extension of Time to File Appellant’s Brief. Appellant requests all other relief to which he may be entitled. Respectfully submitted, /s/ Anton E. Hackebeil ANTON E. HACKEBEIL State Bar No. 08667150 P.O. Box 220 Hondo, Texas 78861 Tel: (830) 741-7001 Fax: (866) 743-4537 Email: tonyhackebeil@att.net ATTORNEY FOR APPELLANT CERTIFICATE OF CONFERENCE I certify that on June 6, 2016, I conferred with counsel for Appellee regarding this motion and Appellee is not opposed to this motion. /s/ Anton E. Hackebeil Anton E. Hackebeil CERTIFICATE OF SERVICE This is to certify that on June 6, 2016, a true and correct copy of Appellant’s First Unopposed Motion for Extension of Time to File Appellant’s Brief was served on counsel for Appellee by the eFileTexas.gov efiling system. /s/ Anton E. Hackebeil Anton E. Hackebeil CERTIFICATE OF COMPLIANCE I certify that this document complies with the typeface requirements of Tex. R. App. P. 9.4(e) because it has been prepared in a conventional typeface no smaller than 14-point font for text. I also certify that this document contains 245 words, excluding any parts exempted by Tex. R. App. P. 9.4(i)(1). /s/ Anton E. Hackebeil Anton E. Hackebeil