John E. Vogt and Nelda L. Vogt v. Marin Real Estate Partners

ACCEPTED
04-15-00636-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
12/2/2015 10:32:23 AM
KEITH HOTTLE
CLERK

NO. 04-15-00636-CV

*** FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
IN THE COURT OF APPEALS 12/2/2015 10:32:23 AM
FOURTH COURT OF APPEALS DISTRICT KEITH E. HOTTLE
Clerk
SAN ANTONIO, TEXAS

***

JOHN E. VOGT and NELDA L. VOGT,
Appellants

v.

MARIN REAL ESTATE PARTNERS, et al.,
Appellees

***

MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

Appellants John Vogt and Nelda Vogt file this Motion to Extend Time to

File Brief as follows:

1. This is an appeal from Cause No. 06-150, John E. Vogt, et al. v.

Marin Real Estate Partners, et al., in the 216th Judicial District Court of Kendall

County, Texas.

2. By Order dated November 13, 2015, the Court ordered the Vogts to

file a jurisdictional brief by December 3, 2015.
 3. The Vogts request an extension until January 15, 2016 to file their

brief.

4. Reasons for the need for an extension:

a. The Vogts’ counsel is a solo practitioner in Kerrville, Texas.

b. As recognized by the Court in its Order, Texas appellate courts
have conflicting opinions about the jurisdictional issue in this
case.

c. Counsel has been unable to complete the Vogts’ brief because
of other commitments and a full litigation docket.

5. Appellees will not be prejudiced by the short extension.

6. This is the only request for an extension of time regarding the Court’s

November 13, 2015 Order.

PRAYER

Appellants John Vogt and Nelda Vogt respectfully request that the Motion

to Extend be granted, that the deadline be extended until January 15, 2016, and

request any other relief to which they may be entitled.

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 Respectfully submitted,

STEPHEN B. SCHULTE, P.C.
Main Plaza One
820 Main Street, Suite 100
Kerrville, Texas 78028
Telephone: (830) 258-4222
Facsimile: (830) 715-9292

________/s/____________________
Stephen B. Schulte
State Bar No. 17836500
Attorney for John Vogt and Nelda Vogt

CERTIFICATE OF SERVICE

I certify that on December 1, 2015, a true copy of this Motion has been
served on all counsel of record as follows:

Roger Bresnahan Via E-Serve

_______/s/____________
Stephen B. Schulte

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