El Caballero Ranch, Inc. A/K/A El Caballero, LLC and Laredo Marine, LLC v. Grace River Ranch, LLC

ACCEPTED
04-15-00127-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
5/27/2015 8:48:24 AM
KEITH HOTTLE
CLERK

No. 04-15-00127CV
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
05/27/2015 8:48:24 AM
FOR THE 4TH JUDICIAL DISTRICT OF TEXAS
KEITH E. HOTTLE
Clerk
AT SAN ANTONIO

EL CABALLERO RANCH, INC.
AND LAREDO MARINE, L.L.C., Appellants

GRACE RIVER RANCH, LLC, Appellee

Appealed from
the 218th District Court of
La Salle County, Texas

AMENDED UNOPPOSED MOTION TO
EXTEND TIME TO FILE APPELLEE'S BRIEF

MOORMAN TATE HALEY
UPCHURCH & YATES, LLP

By: STEVEN C. HALEY
State Bar No. 08741900
207 E. Main St./P.O. Box 1808
Brenham, Texas 77834-1808
Telephone: (979) 836-5664
Telecopier: (979) 830-0913
shaley@moormantate.com

Attorney for Appellee,
Grace River Ranch, LLC

{18705.43065-00386008.DOCX}
No. 04-15-00127CV

IN THE COURT OF APPEALS

FOR THE 4TH JUDICIAL DISTRICT OF TEXAS

AT SAN ANTONIO

EL CABALLERO RANCH, INC.
AND LAREDO MARINE, L.L.C., Appellants

GRACE RIVER RANCH, LLC, Appellee

Appealed from
the 218th District Court of
La Salle County, Texas

AMENDED UNOPPOSED MOTION TO
EXTEND TIME TO FILE APPELLEE'S BRIEF

TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS:

Grace River Ranch, LLC (Grace River), Appellee in this appeal and Plaintiff

below, respectfully files this, its Amended Unopposed Motion to Extend Time to

File Appellee's Brief, and in support of same would show this Court the following:

{18705.43065-00386008.DOCX)
Statement of Facts

1. Summary Judgment in Trial Court. This case originated in the trial court

as an action styled Grace River Ranch, LLC v. El Caballero Ranch, Inc. a/k/a El

Caballero Ranch, LLC and Laredo Marine, LLC v. County of La Salle; No. 13-04-

00108-CV, 218th District Court, La Salle County, Texas.

Motion to Extend Time to File Brief

2. Deadline to File Appellees' Brief. The deadline to file Appellees' Brief is

May 29, 2015.

3. Length of Extension Sought. An extension is sought to file Appellee's

Brief through June 18, 2015.

4. No Previous Extension Sought by Appellee. Appellee has sought no

previous extension of Appellee's briefing deadline.

5. Reason that Extension is Sought. This extension is sought because of the

busy trial schedule of counsel for Appellee. Counsel has two appellate briefs

which are being handled at the same time which is an unusual event. Counsel's

secretary has been out for three weeks due to a severe illness and hospitalization

which has placed things generally behind on all fronts. This extension is not

sought for delay but to allow due consideration of Appellants' Brief and a detailed

response to it.

{18705.43065-00386008DOCX)
WHEREFORE, PREMISES CONSIDERED, Appellee requests an

extension of the within in which to file Appellee's Brief until June 29, 2015.

Respectfully submitted,

MOORMAN TATE EY
CHURCH & Y—

STEVEN C. HALE
State Bar No. 087419
207 East Main
P.O. Box 1808
Brenham, Texas 77834-1808
Telephone: (979) 836-5664
Telecopier: (979) 830-0913
shaley@moormantate.corn

MONTEZ & PATTERSON
John H. Patterson, Jr.
State Bar No. 24027716
Thornton Plaza
508 Thorton, Suite 4
Cotulla, Texas 78014
Telephone: (830) 483-5191
Telecopier: (830) 483-5192
john imontezandpatterson.corn

Attorneys for Appellee,
GRACE RIVER RANCH, L.L.C.

{18705.43065-00386008.DOCX}
CERTIFICATE OF SERVICE

I, Steven C. Haley, do hereby certify that on the 27th day of May, 2015, I
served a true and correct copy of the foregoing Amended Unopposed Motion to
Extend Time to File Appellee's Brief to the following, deposited in a post-paid,
depository under the care and custody of the United States Postal Service, duly
addressed to such party at the address stated, by certified mail, return receipt
requested, facsimile, e-mail, and/or hand-delivery.

Annalyn G. Smith
Schmoyer Reinhard, LLP
17806 I-10W, Ste. 400
San Antonio, Texas 78257
E-mail: asmitha,ar-11p.com

Kimberly S. Keller
Keller Stolarczyk PLLC
234 West Bandera Road, No. 120
Boerne, Texas 78006
E-mail: kim@kellsto.com

Donato D. Ramos
Donato D. Ramos, Jr.
Law Offices of Donato D. Ramos
6721 McPherson
P.O. Box 452009
Laredo, Texas 78045
donatoramosjr@ddrlex.com

STEVEN C. HALEY

{18705.43065-00386008.DOCX}
CERTIFICATE OF CONFERENCE

I hereby certify that on May 18, 2015, I conferr d with oppo ng counsel,
Kimberly S. Keller, who indicates she- does not oppos the foreg ng Motion to
Extend Time to File Appellee's Br. .

STEVEN C. HALEY

{18705.43065-00386008.DOCX}