United Parcel Service, Inc. and Roland Leal v. Robert Scott Rankin, Individually, Rachelle Rankin, Individually and as Next Friend for Avery Rankin, Kara Rankin, and Samuel Rankin, Minors
ACCEPTED
04-014-00494-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
1/15/2015 9:45:06 AM
KEITH HOTTLE
CLERK
NO. 04-014-00494-CV
FILED IN
4th COURT OF APPEALS
IN THE FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS
SAN ANTONIO, TEXAS 01/15/2015 9:45:06 AM
KEITH E. HOTTLE
Clerk
UNITED PARCEL SERVICE, INC. and ROLAND LEAL
Appellants/Cross-Appellees
v.
ROBERT SCOTT RANKIN, Individually; RACHELLE RANKIN,
Individually and as Next Friend for AVERY RANKIN, a Minor; as Next
Friend for KARA RANKIN, a Minor; and as Next Friend for SAMUEL
RANKIN, a Minor
Appellees/Cross-Appellants
On Appeal from the 224th Judicial District Court, Bexar County, Texas
Honorable Cathy Stryker, Presiding Judge
Trial Court Cause No. 2011-CI-07922
APPELLEES’ UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSE BRIEF
TO THE HONORABLE COURT OF APPEALS:
Appellees, Robert Scott Rankin, Rachelle Rankin, Avery Rankin, Kara Rankin,
and Samuel Rankin, by and through their undersigned attorneys, hereby move the
APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 1 of 4
Court for an Order extending the time to file Appellees’ Response Brief, and as
grounds therefor would show the Court the following:
1. Appellees’ Response Brief is due on or before January 20, 2015.
2. Appellees respectfully request that the Court extend their current briefing
deadline of January 20, 2015, to and including January 30, 2015. No previous
extension of time has been granted for the filing of Appellees’ Response Brief.
3. Undersigned counsel has had an unusually busy schedule in December and
January, primarily due to the holiday season and the work required to prepare for
vacation time around the holiday season. Given that, undersigned counsel has not
had, and will not have, an opportunity to properly prepare the brief on the issues in
this matter by the current deadline.
WHEREFORE, Appellees pray that the time for filing their response brief be
extended to and including January 30, 2015; and for such other and further relief as
the Court may deem to be just and proper.
APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 2 of 4
Respectfully submitted,
THE PERRIN LAW FIRM
1910 Pacific Avenue, Suite 6050
Dallas, Texas 75201
Telephone: (214) 646-2004
Facsimile: (214) 646-6117
Email: dougperrin@perrinlaw.org
markperrin@perrinlaw.org
/s/J. Mark Perrin
Doug Perrin
State Bar No. 15796520
J. Mark Perrin
State Bar No. 24013313
REESE GORDON MARKETOS LLP
750 N. St. Paul Street, Suite 610
Dallas, Texas 75201
Telephone: (214) 382-9810
Facsimile: (214) 501-0731
Email: pete.marketos@rgmfirm.com
Pete Marketos
State Bar No. 24013101
KEELING & DOWNES, P.C.
1500 McGowen Street
Houston, Texas 77004
Telephone: (832) 214-9900
Fax: (832) 214-9908
Email: bck@keelingdownes.com
Byron Keeling
State Bar No. 11157980
ATTORNEYS FOR
CROSS-APPELLANTS
APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 3 of 4
CERTIFICATE OF CONFERENCE
I have conferred with counsel for Appellants/Cross-Appellees about the merits
of this Motion and was advised that Appellants/Cross-Appellees do not oppose the
relief requested in this Motion.
Certified this 15th day of January, 2015.
/s/J. Mark Perrin
J. Mark Perrin
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the above and foregoing
document was forwarded to all counsel of record in the above cause through the
Court’s electronic case filing system, on this the 15th day of January, 2015.
Ricardo Reyna
Audrey Haake
Brock, Person, Guerra, Reyna P.C.
17339 Redland Road
San Antonio, Texas 78247
W. Randall Bassett
Bradley Pratt
King & Spalding, LLP
1180 Peachtree Street, NE
Atlanta, Georgia 30309
H. Victor Thomas
King & Spalding, LLP
1100 Louisiana, Suite 4000
Houston, Texas 77002
/s/J. Mark Perrin
APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 4 of 4