ACCEPTED
04-14-00655-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
5/18/2015 9:21:12 PM
KEITH HOTTLE
CLERK
04-14-00655-CV
VICTOR and IVARENE HOSEK
FILED IN
4th COURT OF APPEALS
Appellant SAN ANTONIO, TEXAS
05/18/2015 9:21:12 PM
V.
KEITH E. HOTTLE
Clerk
ROSALE SCOTT
Appellees
ON APPEAL TO THE FOURTH COURT OF APPEALS
FROM THE 81st JUDICIAL DISTRICT COURT
TRIAL CASE NO. 2011-53723
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANTS’ REPLY BRIEF
TO THE HONORABLE COURT OF APPEALS:
COME NOW APPELLANTS, VICTOR and IVARENE HOSEK and file this,
their Motion for extension of time in which to file their brief. Appellants would
show as follows:
1.
Appellants are Victor and Ivarene Hosek, and Appellee is Rosale Scott.
2.
Final judgment on a summary judgment was signed on June 19, 2014. A
Motion for New Trial was filed on July 18, 2014 and Notice of Appeal was filed on
Sept. 17, 2014.
3.
Appellees’ Brief was filed on April 28, 2015. Appellants’ Reply Brief is due
May 18, 2015.
4.
No previous extensions have been granted on the Reply Brief.
5.
The extension requested is fourteen (14) days, until June 1, 2015. Counsel for
the Hosek has been suffering from essential tremors and has had to slow her work
pace down to accommodate them.
6.
The Appellees are not opposed to this extension.
CONCLUSION & PRAYER
The reason for this extension is not for delay but so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, APPELLANTS ask this Court
to extend the deadline for filing their Brief fourteen days until June 1, 2015, and for
such other and further relief as may be just.
Respectfully submitted,
_____/s/ MB CHIMENE_________
THE CHIMENE LAW FIRM
Michele Barber Chimene
TBN 04207500
2827 Linkwood Dr.
Houston, TX. 77025
PH: (832) 940-1471; no fax
michelec@airmail.net
CERTIFICATE OF CONFERENCE
Appellants’ counsel has contacted Raquel Perez, counsel for Appellee, who
stated that she is not opposed to fourteen days.
______/s/ MB CHIMENE________
CERTIFICATE OF SERVICE
A true and correct copy of this Motion for Extension has been served on
counsel for Appellees, Wade Caldwell and Raquel Perez, One Riverwalk Place, Ste.
1825, 700 North St. Mary’s, San Antonio, Texas 78205 on May 18, 2015 by ECF
and email.
______/s/ MB CHIMENE_________