Luz Chavez, Individually, and as Representative of the Estates of Rudolph Chavez, Sr. (Deceased) and Rudolph Chavez, Jr. (Deceased), and as Next Friend of Joel Chavez, a Minor Darlene Chavez Allen Chavez Francisco Chavez And Celia Chavez v. Kansas City Southern Railway Co. and Jose Juarez

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ACCEPTED 04-14-00354-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 1/4/2015 12:31:22 PM KEITH HOTTLE CLERK NO. 04-14-00354-CV THE COURT OF APPEALS FILED IN FOR THE FOURTH DISTRICT OF TEXAS 4th COURT OF APPEALS SAN ANTONIO, TEXAS AT SAN ANTONIO 01/4/2015 12:31:22 PM KEITH E. HOTTLE Clerk ____________________________________________________________________________ LUZ CHAVEZ, INDIVIDUALLY, AND AS REPRESENTATIVE OF THE ESTATES OF RUDOLPH CHAVEZ, SR. (DECEASED) and RUDOLPH CHAVEZ, JR. (DECEASED), AND AS NEXT FRIEND OF JOEL CHAVEZ, A MINOR; DARLENE CHAVEZ; ALLEN CHAVEZ; and CELIA CHAVEZ, APPELLANTS, V. KANSAS CITY SOUTHERN RAILWAY COMPANY and JOSE JUAREZ, APPELLEES. _________________________________________________________ Appeal from the 406th Judicial District Court, Webb County, Texas Honorable Oscar J. Hale, Jr., Judge Presiding _________________________________________________________________________ APPELLANTS’ MOTION TO EXTEND TIME FOR FILING APPELLANTS’ REPLY BRIEF _________________________________________________________________________ Pursuant to Texas Rules of Appellate Procedure 10.5 and 38.6 (c), Appellants respectfully request a two week extension of time in which to file their Reply Brief, as follows: 1. The date on which Appellants’ Reply Brief is currently due is January 5, 2015. 2. Appellants hereby request a two week extension of time on which to file their reply brief. 3. An extension of time is needed due to conflicting and concurrent deadlines in the prosecution of other cases, which include a hearing on a motion for summary judgment on January 5, 2015, and a final hearing on January 7, 2015, and travel to be with family on Christmas and New Year’s Day. 1 4. No previous extensions have been requested, or granted, with respect to the date of filing of Appellants’ Reply Brief. WHEREFORE, Appellants respectfully request a two week extension of time in which to file their reply brief. Respectfully submitted, /s/ Mark Alvarado By: ___________________________ Mark Alvarado State Bar No. 01126520 Law Office of Mark Alvarado 9600 Escarpment Blvd., Suite 745 Austin, Texas 78749 Telephone: (512) 287-9469 Facsimile: 512-582-8651 alvarado_mark@hotmail.com ATTORNEY FOR APPELLANTS 2 CERTIFICATE OF CONFERENCE Counsel for Appellants attempted to confer with counsel for Appellees before filing the last Motion, but was unable to reach him. /s/ Mark Alvarado By: ___________________________ Mark Alvarado 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on all parties through their respective attorneys of record, in accordance with the Texas Rules of Civil Procedure, via efile.texcourts.gov electronic mail, and/or facsimile, on this the 5th day of January, 2015, as follows: Merritt Clements Donato D. Ramos, Sr. Strasburger Law Offices of Donato D. Ramos 2301 Broadway St., P. O. Box 452009 San Antonio, Texas 75215 Laredo, Texas 78045-2009 Phone (210) 250-6005 Phone (956) 722-9909 Fax (210) 258-2717 Fax (956) 727-5884 merrit.clements@strasburger.com Attorneys for Defendants Kansas City Southern Railway and Jose Juarez Lynn Watson Rosenthal & Watson, P.C. 6601 Vaught Ranch Road, Suite 200 Austin, Texas 78730-2309 lwatson@rosenthalwatson.com Attorney for Intervenor Rosenthal & Watson, PC Matthew Wagner Bartlett & Schober, P.C. 1611 Nueces Street Austin, Texas 78701 512-474-7678 512-597-3510 Fax mwagner@bartlettschober.com Attorney for Mr. Ron Satija Trustee for Estate of Rosenthal & Watson, PC /s/ Mark Alvarado ______________________ Mark Alvarado 4