Ramiro and Edna Ramos, and Federico Salazar, Jr. v. the Unknown Heirs of Tomasa Gonzalez and Narciso Gonzalez

ACCEPTED
04-14-00667-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/30/2015 3:17:43 PM
KEITH HOTTLE
CLERK

CAUSE NUMBER 04-14-667-CV
_____________________________ FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
RAMIRO AND EDNA RAMOS AND 06/30/2015 3:17:43 PM
FEDERICO SALAZAR, JR., APPELLANTS KEITH E. HOTTLE
Clerk
V.

THE UNKNOWN HEIRS OF
TOMASA GONZALEZ AND
NARCISO GONZALEZ, APPELLEES
____________________________

IN THE FOURTH COURT OF APPEALS
SAN ANTONIO TEXAS
_____________________________

ON APPEAL FROM THE
st
381 JUDICIAL DISTRICT COURT
TRIAL CAUSE NO. DC-09-559
HON. J. MANUEL BANALES,
PRESIDING JUDGE
____________________________

THE APPELLEES’ FIRST UNOPPOSED
MOTION FOR EXTENSION OF TIME
TO FILE THEIR BRIEF
________________________________

TO THE HONORABLE JUSTICES OF SAID COURT:

The Appellees motion this Court for an extension of time to file their Brief and,

in support hereof, show the following:

HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION.mot Page 1 of 4
 I. DEADLINE

The Appellees’ Brief was due on or before 5:00 PM, 29 June. As of the

moment this Motion was filed, no submission date has been scheduled.

II. LENGTH OF TIME SOUGHT FOR EXTENSION

The undersigned motions for an Order of this Court allowing for an extension

of time to file the Appellees’ Brief to on or before 5:00 PM, Friday, 3 July 2015.

III. THE FACTS IN SUPPORT OF THIS MOTION

He was unable to timely-file the Appellees’ Brief because he appreciated at

about 3:00 PM on 29 June, as he was proof-reading his penultimate draft, that his

laptop and/or USB drive had apparently become infected with some sort of a virus

that either prevented him from accessing downloaded material in one or both, or

prevented him from editing the same, thereby causing him to have to spend more

needed and valuable time to quickly deliver them both for inspection and repairs, and

then, on another laptop, basically have to start all over from memory and conduct a

second review for cases, authorities, etc., he could recall having located.

IV. NUMBER OF EXTENSIONS.

This is the Appellees’ first extension Motion.

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 V. CONFERENCE WITH THE
APPELLANTS’ APPELLATE COUNSEL

Fortuitously, however, the undersigned had previously spoken to the

Appellants’ lead appellate counsel, Mr. Keith P. Miller, about the possibility of

asking for a short extension of time (albeit for a different basis), and Mr. Miller

graciously notified him that he would have no opposition to a short extension, were

the same to be necessary.

Based on the foregoing facts, the undersigned motions this Court for an Order

allowing for an extension of time to file the Appellees’ Brief to on or before 5:00 PM,

Friday, 3 July 2015.

Respectfully Submitted By:

____ / JOHN A. OLSON/ ________

JOHN A. OLSON
Tex. Bar No. 15274750
20634 Creek River
San Antonio TX 78259-2084
210-307-0336 Office
210-858-6780 Fax
jaolson_ccda@yahoo.com

HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION.mot Page 3 of 4
 CERTIFICATE OF SERVICE

A copy of this FIRST UNOPPOSED MOTION, etc., was sent on 30 June 2015 to the

Appellants’ appellate counsel, Mr. Kenneth P. Miller and Ms. Megan C. Kucera, C/O

Miller & Kucera, 10500 Heritage Blvd., Suite 107, San Antonio TX 78216 by email

and first class mail.

___ /JOHN A. OLSON/ ________

JOHN A. OLSON
jaolson_ccda@yahoo.com

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