ACCEPTED
04-14-00740-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/15/2015 11:14:54 AM
KEITH HOTTLE
CLERK
NO. 04-14-00740-CV
FILED IN
4th COURT OF APPEALS
IN THE COURT OF APPEALS SAN ANTONIO, TEXAS
FOR THE FOURTH JUDICIAL DISTRICT OF 04/15/2015
TEXAS 11:14:54 AM
AT SAN ANTONIO KEITH E. HOTTLE
Clerk
ART REYNA,
Appellant,
v.
IRENE BALDRIDGE AND KATHY HILL,
Appellees.
ON APPEAL FROM THE 285th JUDICIAL DISTRICT COURT
BEXAR COUNTY, TEXAS
TRIAL COURT NO. 2014-CI-03985
THE HONORABLE JUDGE CATHLEEN M. STRYKER PRESIDING
UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLANT’S REPLY BRIEF
TO THE HONORABLE JUSTICES OF THE COURT:
Under Texas Rules of Appellate Procedure 10.5(b)(1) and 38.6(d), Appellant
Art Reyna, referred to as Appellant, respectfully moves the Court to extend the time
for filing Appellant’s Reply Brief. As good cause, Appellant respectfully shows the
Court the following:
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1. Appellees Irene Baldridge and Kathy Hill filed their Appellees’ Brief on
March 26, 2015.
2. Under Texas Rule of Appellate Procedure 38.6(c), Appellant’s Reply Brief is
currently due on or before April 15, 2015.
3. Appellant requests that the Court extend the time to file Appellant’s Reply
Brief seven (7) days. A seven (7) day extension would make the Appellant’s Reply
Brief due on April 22, 2015.
4. In support of the requested extension, Appellant would show that Appellees
cited numerous lengthy cases in their Appellees’ Brief that require analysis to
prepare a proper reply, in addition to analysis of recent cases decided or pending
under Tex. Civ. Prac. & Rem. Code Chapter 27, which serves as the basis of this
appeal.
5. In addition, counsel for Appellant, Ronald B. Prince and Floyd Steven
Contreras, had commitments during the time to reply that required their time and
attention and interfered with preparation of Appellant’s Reply Brief by the current
deadline, including the following:
Preparation for trial and trial in Cause No. 21DC1401864, Troy Capital, LLC
v. Elvira Eardley-Thrash, in Justice Court, Precinct 2, Bexar County, which took
place on April 14, 2015.
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6. This is Appellant’s first request for an extension of time to file Appellant’s
Reply Brief. Appellant seeks this extension not solely for delay, but so that justice
may be done.
7. As reflected in the Certificate of Conference below, counsel for Appellees
indicated that they are unopposed to this motion.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant Art Reyna
respectfully requests that the Court grant a seven (7) day extension of time to file
Appellant’s Reply Brief, extending the time to file Appellant’s Reply Brief until
April 22, 2015.
Appellant further prays for such other relief to which he may be entitled.
Respectfully submitted,
PRINCE CONTRERAS PLLC
417 San Pedro Avenue
San Antonio, Texas 78212
Tel: (210) 227-7821
Fax: (210) 225-4469
info@princecontreras.com
ATTORNEYS FOR ART REYNA
_/s/ Floyd Steven Contreras_____________
RONALD B. PRINCE
State Bar No. 16329300
ron@princecontreras.com
FLOYD STEVEN CONTRERAS
State Bar No. 24075339
floyd@princecontreras.com
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CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with Edward P. Cano and Darby Riley,
counsel for Appellees, regarding our Motion to Extend Time to File Appellant’s
Reply Brief.
Both Mr. Cano and Mr. Riley indicated that they are unopposed to our motion.
_/s/ Floyd Steven Contreras_____________
RONALD B. PRINCE
FLOYD STEVEN CONTRERAS
CERTIFICATE OF SERVICE
I hereby certify that on the 15th day of April, 2015, a true and correct copy of
the foregoing Unopposed Motion to Extend Time to File Appellant’s Reply Brief
was served on the following counsel of record electronically through the electronic
filing manager:
Mr. Edward P. Cano
201 W. Poplar St.
San Antonio, Texas 78212
Tel: (210) 223-1099
Fax: (210) 212-5653
edcanoattorney@sbcglobal.net Attorney for Appellees
Mr. Darby Riley
RILEY & RILEY
320 Lexington Avenue
San Antonio, Texas 78215
Tel: (210) 225-7236
Fax: (210) 227-7907
darbyriley@rileylawfirm.com Attorney for Appellees
_/s/ Floyd Steven Contreras_____________
RONALD B. PRINCE
FLOYD STEVEN CONTRERAS
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