ACCEPTED
04-14-00812-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
3/11/2015 3:16:07 PM
KEITH HOTTLE
CLERK
Appeal No. 04-14-00812-CV
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
FOR SAN ANTONIO, TEXAS
03/11/2015 3:16:07 PM
THE FOURTH SUPREME JUDICIAL DISTRICT
SAN ANTONIO, TEXAS KEITH E. HOTTLE
Clerk
IN THE ESTATE OF CONSUELLA PERKINS ULBRICH, DECEASED,
DOUGLAS J. ULBRICH
Appellant
v.
ROBERT HOPE, DARLENE WILSON and DEBRA BYRD
Appellees
From the Probate Court No. 1,
Bexar County, Texas
Honorable Pooly Jackson Spencer, Presiding
____________________________________________________________
APPELLEES’ MOTION FOR EXTENSION
OF TIME TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Appellees, Robert Hope, Darlene Wilson and Debra
Byrd(hereinafter “Appellees”), file this their Motion for
Extension of Time to File Appellees’ Opening Brief in the
above-referenced cause pursuant to Texas Rules of Appellate
Motion for Extension of Time to File Appellees’ Brief Page 1
Procedure 38.6(d) and 10.5(b), and in support thereof, would
show this Honorable Court as follows:
1. Pursuant to Texas Rule of Appellate Procedure
38.6(b), Appellees’ deadline to file their Appellees’ Opening
Brief is today, Wednesday, March 11, 2015.
2. This is Appellees’ first request for extension of
time to file their Appellees’ Opening Brief.
3. Appellees respectfully request an approximately
thirty (30) day extension to file their Appellees’ Opening
Brief - until Friday, April 10, 2015.
4. Appellees request this extension because the
undersigned has had insufficient time to adequately prepare a
cogent and succinct response to Appellant’s Opening Brief.
5. Appellees request this extension not for purposes of
delaying this appeal, but so that justice may be done.
Respectfully submitted,
Arlitt Law Firm, LLC
By: /s/ Kristine Arlitt
KRISTINE ARLITT, ESQ.
Texas Bar No. 24034117
206 Locust Street
San Antonio Texas 78209
Telephone 210.821.6101
Telecopier 210.821.6105
Motion for Extension of Time to File Appellees’ Brief Page 2
Attorney for Appellees
Of Counsel:
Crist Law Firm, PLLC
By: /s/ William D. Crist
WILLIAM D. CRIST, ESQ.
Texas Bar No. 24043614
3123 N.W. Loop 410
San Antonio Texas 78230
Telephone 210.340.3277
Telecopier 210.372.0400
Attorney for Appellees
Motion for Extension of Time to File Appellees’ Brief Page 3
CERTIFICATE OF CONFERENCE
I received an email today, March 11, 2015, from opposing
counsel, Philip M. Ross stating he is opposed to the thirty
day extension.
/s/ William D. Crist
William D. Crist
CERTIFICATE OF SERVICE
I certify that on the 11th day of March, 2015, a true copy
of this Motion for Extension of Time to File Appellees’ Brief
was served on the following:
Philip M. Ross
Attorney for Appellant
1006 Holbrook Road
San Antonio, Texas 78218
Via Facsimile to 210.590.2509
/s/ William D. Crist
William D. Crist
Motion for Extension of Time to File Appellees’ Brief Page 4