ACCEPTED
04-15-00392-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
9/21/2015 3:40:29 PM
KEITH HOTTLE
CLERK
No. 04–15–00392–CV
JOYCE ANN SARRO IN THE COURT FILED
OF APPEALS
IN
4th COURT OF APPEALS
vs. 4TH COURT OF APPEALS DISTRICT
SAN ANTONIO, TEXAS
9/21/2015 3:40:29 PM
MICHAEL A. SARRO SAN ANTONIO, TEXAS
KEITH E. HOTTLE
Clerk
Motion for Extension of Time To File a Brief by Appellant
(Unopposed)
Comes now appellant, Joyce Ann Sarro, and moves the Court to extend the time to
file her brief, pursuant to Tex. R. App. P. 10.1, 10.5, and Article I, section 19 of the Texas
Constitution.
1. Appellant’s brief is presently due on September 21, 2015.
2. An extension for 30 days is requested to October 21, 2015.
3. The undersigned counsel for Appellant has been responsible for the care of two
family members, one of whom passed away in June 2015. His brother, handicapped with
Down’s Syndrome, has additional difficulties including the necessity of being prompted
when eating. On August 31, 2015, the brother was hospitalized and was released on
September 5, 2015. A copy of the discharge document is attached as exhibit ’A’ and is
made a part of this motion. This new development has required additional attention.
4. This is the first request for an extension of time to file a brief by Appellant.
5. This extension is not sought solely for delay, but that justice may be done.
6. An inquiry was made about this motion to the attorney for Appellee, who indicated
that the motion is not opposed.
Prayer
Therefore, Joyce Ann Sarro prays that this motion be filed, that an extension of time
be granted to October 21, 2015 to file Appellant’s brief, and that she have such other relief,
in law or equity, to which she may be justly entitled.
1
Respectfully submitted,
/s/ R. Robert Willmann, Jr.
R. Robert Willmann, Jr.
Attorney at Law
P.O. Box 460167
San Antonio, Texas 78246
Tel 844.244.9973
Temporary Fax 361.552.4305
willaw@prismnet.com
Bar No. 21655960
Certificate of Service
I certify that this motion was served by–
electronic service through an electronic filing manager and by fax to Rachel Sadovsky;
Cordell & Cordell; 10101 Reunion Place, Suite 250; San Antonio, Texas 78216
(rsadovsky@cordelllaw.com) (attorney for Michael A. Sarro);
on the 21st day of September, 2015.
/s/ R. Robert Willmann, Jr.
R. Robert Willmann, Jr.
2
Exhibit A
Affidavit Regarding Exhibit
State of Texas
County of Calho~~n
Before me, the undersigned authority, personally appeared R. Robert Wdlmam, Jr.,
who, after being duly sworn, stated as follows.
"I, R. Robert Willmann, Jr., am over 18 years of age, am an attorney licensed to
practice law in the State of Texas, and am otherwise competent to make this affidavit.
:^.
I am an attorney for appellant Joyce Ann Sarro regarding this appeal.
Attached to this affidavit and made a part of this exhibit 'A' is a true and complete copy
of a discharge sheet for my brother David Wilhnann regarding his recent hospitalization,
with some redactions. I signed the paper at the hospital and received a copy there.
I have personal knowledge of the contents of this affidavit and they are true and
correct."
R. Robert Willmann, Jr.
Affiant d
Subscribed and sworn to before me on this 18th day of September, 2015, to which witness
my hand and seal of office.
A 4
NO& Public, State of Texas
/
My commission expires:
Discharge Instructions
Printed: 09/05/15 20:09 Page 2 of 2
L MEDICATIONS
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Prescription Detail- TAKE 3 mill1 rams BY MOUTH EVERY EVENING
Next Dose Due: 09/05/2015 5:00 ?M
PLEASE STOP TAKING ALL MEDICATIONS LISTED BELOW
BY MOUTH
Shop~houte:
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Frequency: DAILY
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1 REFERRALS / TRANSITIONS OF CARE 1
Transition of Care
Provider : BETHANY HOME HEALTH
Phone :
Address1 :
Address2 :
City:
State:
Zip: 00000
Reason for Transfer:
Scheduled Date:
Additional Information:
Patient's signature:
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PATIENT:
-- WILLMANN DAVID NUMBER : .
NUMBER: -----', AGE: 59 SEX : ROOM: 105 PAG