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.
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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
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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
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