ACCEPTED
04-14-00551-cv
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
1/20/2015 9:51:38 PM
KEITH HOTTLE
CLERK
NO. 04-14-00551-CV
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
FOR THE SAN ANTONIO, TEXAS
01/20/2015 9:51:38 PM
FOURTH JUDICIAL DISTRICT OF TEXAS
KEITH E. HOTTLE
SAN ANTONIO, TEXAS Clerk
PABLO SOLIZ § APPELLANT
§
V. §
§
STATE OF TEXAS § APPELLEE
APPEAL FROM 79th JUDICIAL DISTRICT COURT
BROOKS COUNTY, TEXAS
TRIAL COURT NO. 14-02-16542-CV
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE
SUPPLEMENTED BRIEF ADDING CITATIONS TO CLERK’S
RECORD
________________________________________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes, Pablo Soliz, Appellant in the above entitled and numbered
cause, by and through his pro bono attorney of record, Rick Soliz, and in reply
to this court’s order dated January 5, 2015, submits this First Motion for
Extension of Time to File Appellant's Supplemented Brief (with citations) and
moves for 30 days, until February 19, 2015. In the alternative, 20 days is
sought. For good cause, Appellant shows as follows.
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Appellant’s supplemented brief with citations brief is due January 20,
2015. Appellant counsel, a trial attorney, seeks to do the best job possible on
the supplemented brief and respectfully requests additional time to perfect the
brief. Moreover, the clerk’s record was submitted to this Court late, incomplete
and defective. The latest and last defect was cured by this Court’s staff, on
January 14, 2015, by adding numeration in order for all parties to be able to
better reference such record. Appellant has provided such corrected copy to
appellee’s counsel. Appellant did request all records in the matter below in such
case this Court found the record useful. This is in spite of the fact that this is
only a documentary evidence proceeding below regarding a partial motion for
summary judgment.
Additionally, Movant, who maintains a full time solo practice, has been
slowed by what should be a temporary illness that required a doctor office visit
on January 9, 2015 and subsequent medication. It seems another doctor visit
will be necessary this week.
In addition, the undersigned counsel has attended two previously
scheduled continuing education seminars during the court ordered timeframe to
supplement the brief. One local CLE program for attorneys on January 15, 2015
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and one three day, out of town CE program for elected officials on January 16,
2015 through January 18, 2015.
This Motion is not made for delay, but to see that justice is done.
Prayer
Wherefore, premises considered, Appellant prays that the deadline for
filing Appellant's Brief be extended to February 19, 2015.
Certificate of Service
This is to certify that a true and correct copy of the attached and foregoing
document will be served on the Kent Richardson, counsel for Appellee.
Respectfully submitted,
/S/ Rick Soliz
Rick Soliz
T.B.N. 00785013
P.O. Box 4051
Houston, Texas 77210
713-228-1900
jrsoliz@att.net
Attorney for Appellant
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