ACCEPTED
04-14-00547-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
2/12/2015 3:52:30 PM
KEITH HOTTLE
CLERK
No. 04-14-00547-CV
IN THE
FILED IN
COURT OF APPEALS 4th COURT OF APPEALS
FOR THE SAN ANTONIO, TEXAS
FOURTH SUPREME JUDICIAL DISTRICT OF TEXAS
02/12/2015 3:52:30 PM
AT SAN ANTONIO, TEXAS KEITH E. HOTTLE
Clerk
IN THE INTEREST OF T.S.P., A CHILD
APPELLEE'S MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS, FOURTH
DISTRICT OF TEXAS:
COMES NOW, MARSALIE ZINSMEYER, the appellee in the above styled and
numbered cause, pursuant to Texas Rules of Appellate Procedure 10.5(b) and 49.8, through her
attorney of record, files this motion to extend time to file her Appellee’s brief. In support of this
motion the appellee respectfully shows the following:
1. On January 16, 2015, Appellant’s brief was filed in this case.
2. The deadline for filing the Appellee’s brief in this appeal was set for February 16, 2015.
3. The Appellee seeks a fourteen-day extension of time to file her brief, making the due date
March 2, 2015.
4. Appellee seeks this extension of time to file her brief because Attorney Shawn H. Smith,
has had multiple scheduling conflicts over the past month, including several felony cases
which needed to be disposed of through trial or hearings and demanded a large
investment of time.
5. No previous extensions of time to file the motion for rehearing in this cause have been
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sought or granted.
6. The undersigned counsel does not believe the additional time requested will prejudice or
inconvenience the Appellant.
PRAYER
THEREFORE, the Appellee prays that this Court issue an order granting the extension of time to
file the Appellee’s Brief in the above case, and grant all such relief as is fair and just.
Respectfully submitted,
LAW OFFICES OF SHAWN H. SMITH, P.C.
Shawn H. Smith
1919 San Pedro
San Antonio, TX 78212
Phone: 512-576-3380
Fax: 866-572-6413
/s/ Shawn H. Smith
Shawn H. Smith
State Bar Number: 24079361
ATTORNEY FOR APPELLEE
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a copy of the above motion was delivered on
August 25, 2013 to the State’s Attorney: Susan D. Reed, Criminal District Attorney, Bexar
County District Attorney’s Office, 101 W. Nueva St., Suite 370, San Antonio, Texas 78205.
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