David Medrano v. Celine Hinojosa

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ACCEPTED 04-14-00913-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 10/19/2015 2:52:44 PM KEITH HOTTLE CLERK No. 04-14-00913-CV IN THE FILED IN 4th COURT OF APPEALS FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS SAN ANTONIO 10/19/2015 2:52:44 PM KEITH E. HOTTLE Clerk DAVID MEDRANO, Appellant, v. FIDELITY NATIONAL TITLE INSURANCE COMPANY, SUCCESSOR BY MERGER LAWYERS TITLE INSURANCE CORPORATION, BARCLAYS CAPITAL REAL ESTATE INC. D.B.A. HOMEQ, AS SERVICING AGENT FOR DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE, ET AL, Appellees. ON APPEAL FROM THE 37TH JUDICIAL DISTRICT COURT BEXAR COUNTY, TEXAS CAUSE NUMBER 2008-CI-00027 UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE FIDELITY NATIONAL TITLE INSURANCE COMPANY’S BRIEF TO THE HONORABLE COURT OF APPEALS: Appellee, Fidelity National Title Insurance Company, Successor by Merger with Lawyers Title Insurance Corporation (“Fidelity”), respectfully files this unopposed motion for extension of time to file its Appellee’s brief. 1 1. Appellant David Medrano filed Appellant’s brief on September 17, 2015, after obtaining three extensions of the deadline to file his brief. 2. The current deadline for filing Appellees’ brief is October 19, 2015. 3. Fidelity seeks a 30-day extension until November 18, 2015 of the deadline in which to file its brief. 4. This motion is unopposed. This is Fidelity’s first request for an extension of its briefing deadline. 5. The Court has also granted a thirty-day extension to Appellee Deutsche Bank National Trust Company, Trustee in which to file its brief. 6. The following grounds provide good cause for extending the time to file the brief. Counsel for Fidelity has been and continues to be engaged in other litigation with imminent deadlines that will prevent them from completing Appellees’ brief before the deadline, including, but not limited to, the following: • Preparation for jury trial in 2012-CI-13430, Stephen Torres v. City of San Antonio et al., in the 224th District Court, Bexar County, Texas. Jury trial was set for October 19, 2015. On Friday, October 16, 2015, counsel received an Order from the Court granting a motion for summary judgment on the case. However, this was not before counsel was required to prepare for the jury trial that was expected to last one to two weeks. 2 • Preparation and attendance at a mediation of Cause No. 2014-CI- 01756; Alamo Fireworks, Inc. v. Mr. W Fireworks, Inc.; In the 150th Judicial District Court, Bexar County, Texas. The mediation occurred on October 7, 2015. 7. This motion is not filed for the purpose of delay, but to allow Fidelity’s counsel adequate time to prepare its brief. For these reasons, Appellee, Fidelity National Title Insurance Company, Successor by Merger with Lawyers Title Insurance Corporation, respectfully requests the Court grant an extension of time to file its Appellee’s brief until November 18, 2015. Respectfully submitted, By: /s/ Aaron M. Barton Fred R. Jones Texas Bar No. 10886700 jones@goodelaw.com Aaron M. Barton Texas Bar No. 24059430 barton@goodelaw.com Goode, Casseb, Jones Riklin, Choate & Watson, P.C. P.O. Box 120480 San Antonio, Texas 78212 Telephone: (210) 733-6030 Facsimile: (210) 733-0330 Attorneys for Fidelity National Title Insurance Company, Successor by Merger with Lawyers Title Insurance Corporation 3 CERTIFICATE OF CONFERENCE I, Aaron M. Barton, certify that I conferred with counsel for Appellant and counsel for all other Appellees on October 19, 2015, and counsel for all parties stated they are unopposed to the requested extension. /s/ Aaron M. Barton Aaron M. Barton CERTIFICATE OF SERVICE I hereby certify that on October 19, 2015, a true and correct copy of the foregoing was sent by facsimile, as follows: Gregory T. Van Cleave The Law Office of Albert W. Van Cleave, III PLLC 1520 W. Hildebrand San Antonio, TX 78201 Thomas E. Quirk Aaron & Quirk Law Offices of Aaron & Quirk 8700 Crownhill Boulevard, Suite 600 San Antonio, Texas 78209 Valerie Henderson Kari Robinson Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C. 1301 McKinney Street, Suite 3700 Houston, Texas 77010 /s/ Aaron M. Barton Aaron M. Barton 4