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
7/7/2015 10:52:06 AM
KEITH HOTTLE
CLERK

CAUSE NUMBER 04-14-667-CV
_____________________________ FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
RAMIRO AND EDNA RAMOS AND 07/7/2015 10:52:06 AM
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’ SECOND
MOTION FOR EXTENSION OF TIME
TO FILE THEIR COMPANION BRIEF
________________________________

TO THE HONORABLE JUSTICES OF SAID COURT:

The Appellees again motion this Court for an extension of time to file their

companion Brief and, in support hereof, show the following:

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 I. DEADLINE

The Appellees were granted an extension of time to file their Brief to on or

before 5:00 PM, 3 July. As of the moment this Second Motion was filed, no

submission date has been scheduled.

II. LENGTH OF TIME SOUGHT FOR
A SECOND EXTENSION

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

of time to file the Appellees’ companion Brief to the date it is marked received.

III. THE FACTS IN SUPPORT OF THIS MOTION

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

thought were being done to allow him access to his laptop’s content took longer than

he was told they would, and when he finally got the laptop back, some of the same

problems he encountered the first time it began malfunctioning reoccurred.

Therefore, he had to return it for more work, and it was only by 10:00 AM,

Monday 6 July that he was able to start again on his penultimate draft to draft his

final draft, which is filed along with this Motion.

Finally, the undersigned had a major breakdown of his car, which caused the

loss of more valuable time.

HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION2.mot Page 2 of 4
 IV. NUMBER OF EXTENSIONS.

This is the Appellees’ second Motion, and will be the last because their Brief is

also being filed.

V. CONFERENCE WITH THE
APPELLANTS’ APPELLATE COUNSEL

The undersigned did not confer with Mr. Miller about his position respecting

this Second Motion because he decided to concentrate on getting the companion Brief

filed with this Motion.

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

allowing for an extension of time to file the Appellees’ companion Brief on the date it

is received.

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\EXTENSION2.mot Page 3 of 4
 CERTIFICATE OF SERVICE

I delivered a copy of this SECOND MOTION, etc., to the Law Offices of Mr. Keith

P. Miller and Ms. Megan C. Kucera, the Appellants’ Attorneys, on 7 July 2015.

___ /JOHN A. OLSON/ ________

JOHN A. OLSON
jaolson_ccda@yahoo.com

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