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
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.
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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
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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
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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
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