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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