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

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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.   1   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   2   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   3