ACCEPTED
01-14-00552-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/10/2015 2:32:31 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00552-CV
*** FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURT OF APPEALS 4/10/2015 2:32:31 PM
FIRST COURT OF APPEALS DISTRICT
CHRISTOPHER A. PRINE
Clerk
HOUSTON, TEXAS
***
MARIBEL AMBRIZ MARTINEZ, GUADALUPE MOTA,
AND ROSA NELLY TREVINO,
Appellants,
v.
ALFREDO GONZALEZ,
Appellee.
***
On Appeal from the 365th Judicial District Court
of Maverick County, Texas
***
APPELLANTS’ SECOND UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE REPLY BRIEF
TO THE HONORABLE FIRST COURT OF APPEALS:
MARIBEL AMBRIZ MARTINEZ, GUADALUPE MOTA, and
ROSA NELLY TREVINO, Appellants in this matter, respectfully file
this motion requesting an extension of time to file their reply brief in
this cause. By this motion, Appellants seek an extension of 21 days
from the current due date of April 15, 2015 to May 6, 2015. Counsel for
Appellee does not oppose the relief sought by this motion.
I.
Following two extensions of time, Appellants filed their brief on
December 5, 2014. Appellee likewise received two extensions of time to
file his brief and filed that brief on March 6, 2015. Appellants have
previously filed one motion for extension of time -- and were granted an
additional 20 days -- to file their reply brief, which is presently due to be
filed on or before April 15, 2015.
II.
In the time preceding the due date for Appellants’ reply brief, the
undersigned has had the following commitments that have prevented
immediate work on the brief and its completion by the current deadline.
Those commitments include, but are not limited to, the following:
(1) legal research concerning post-verdict motions and potential
appellate issues in Marshall v. Catholic Health Initiatives, Inc., Civil
Action No. 11-CI-00972, in the 27th Judicial Circuit, Laurel Circuit
Court Division II, of the Commonwealth of Kentucky by March 31,
2015;
(2) preparing responses to multiple motions for summary
judgment by April 2, 2015 in Cause No. 2014-CVT000757-D3, Trevino,
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 2
et al. v. Union Pumping, L.P., et al., pending in the 341st Judicial
District Court of Webb County, Texas;
(3) extensive legal research to facilitate revision of pleadings
and discovery in Cause No. 13-2531, Carlton v. Media Nation Outdoor,
LLC, et al., in the 22nd Judicial District Court of Hays County, Texas
by April 9, 2015; and
(4) family and religious commitments over the extended Holy
Week holiday (April 3, 2015 through April 5, 2015).
III.
In light of the foregoing, Appellants respectfully request a 21-day
extension of time, from April 15, 2015 to May 6, 2015, to file their reply
brief.
IV.
This extension is not sought for purposes of delay. It is requested
because of the above-mentioned circumstances, along with the regular
interruptions of a busy law practice.
WHEREFORE, PREMISES CONSIDERED, Appellants Maribel
Ambriz Martinez, Guadalupe Mota, and Rosa Nelly Trevino respectfully
request that this motion be granted and that the time for filing their
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 3
brief be extended by 21 days from April 15, 2015 to May 6, 2015.
Appellants also respectfully pray for such other and further relief to
which they may be entitled.
Respectfully submitted,
WATTS GUERRA, LLP LAW OFFICE OF MICHAEL MILLER
Michael J. Murray Michael Miller
State Bar No. 24007721 State Bar No. 00788060
mmurray@wattsguerra.com mmiller@michaelmillerlaw.com
Francisco Guerra IV 926 Chulie Drive
State Bar No. 00796684 San Antonio, Texas 78216
fguerra@wattsguerra.com (210) 225-6666 (telephone)
Shalimar S. Wallis
State Bar No. 24033191
swallis@wattsguerra.com
300 Convent Street, Suite 100
San Antonio, Texas 78205
(210) 527-0500 (telephone)
/s/ Michael J. Murray .
Michael J. Murray
ATTORNEYS FOR APPELLANTS
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 4
CERTIFICATE OF CONFERENCE
Pursuant to Texas Rule of Appellate Procedure 10.1(a)(5), on April
10, 2015, the undersigned conferred with Ms. Elizabeth Conry Davidson,
attorney for Appellee. Ms. Davidson advised that Appellee does not
oppose the relief Appellants seek by this motion.
/s/ Michael Murray .
Michael J. Murray
CERTIFICATE OF SERVICE
I certify that the foregoing document was electronically filed with
the Clerk of the Court using the electronic filing system of the Court. I
also certify that a true and correct copy of the foregoing was served via
e-service or e-mail on the following counsel of record on April 10, 2015:
Carl J. Kolb Elizabeth Conry Davidson
CARL J. KOLB, P.C. Attorney at Law
926 Chulie Drive 926 Chulie Drive
San Antonio, Texas 78216 San Antonio, Texas 78216
Counsel for Appellee Alfredo Gonzalez
/s/ Michael J. Murray .
Michael J. Murray
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 5
Maribel Ambriz Martinez, Guadalupe Mota, Rosa Nelly Trevino v. Alfredo Gonzalez
Combined Opinion