El Caballero Ranch, Inc. A/K/A El Caballero, LLC and Laredo Marine, LLC v. Grace River Ranch, LLC

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ACCEPTED 04-15-00127-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 5/27/2015 8:16:24 AM KEITH HOTTLE CLERK No. 04-15-00127CV FILED IN IN THE COURT OF APPEALS 4th COURT OF APPEALS SAN ANTONIO, TEXAS 05/27/2015 8:16:24 AM FOR THE 4TH JUDICIAL DISTRICT OF TEXASKEITH E. HOTTLE Clerk AT SAN ANTONIO EL CABALLERO RANCH, INC. AND LAREDO MARINE, L.L.C., Appellants V. GRACE RIVER RANCH, LLC, Appellee Appealed from the 218th District Court of La Salle County, Texas UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF MOORMAN TATE HALEY UPCHURCH & YATES, LLP By: STEVEN C. HALEY State Bar No. 08741900 207 E. Main St./P.O. Box 1808 Brenham, Texas 77834-1808 Telephone: (979) 836-5664 Telecopier: (979) 830-0913 shaley@moormantate.com Attorney for Appellee, Grace River Ranch, LLC {18705.43065-00384445.DOCX} No. 04-15-00127CV IN THE COURT OF APPEALS FOR THE 4TH JUDICIAL DISTRICT OF TEXAS AT SAN ANTONIO EL CABALLERO RANCH, INC. AND LAREDO MARINE, L.L.C., Appellants V. GRACE RIVER RANCH, LLC, Appellee Appealed from the 218" District Court of La Salle County, Texas UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEE'S BRIEF TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS: Grace River Ranch, LLC (Grace River), Appellee in this appeal and Plaintiff below, respectfully files this, its Unopposed Motion to Extend Time to File Appellee's Brief, and in support of same would show this Court the following: 2 {18705.43065-00384445.DOCX} Statement of Facts 1. Summary Judgment in Trial Court. This case originated in the trial court as an action styled Grace River Ranch, LLC v. El Caballero Ranch, Inc. a/k/a El Caballero Ranch, LLC and Laredo Marine, LLC v. County of La Salle; No. 13-04- 00108-CV, 218th District Court, La Salle County, Texas. Motion to Extend Time to File Brief 2. Deadline to File Appellees' Brief. The deadline to file Appellees' Brief is May 29, 2015. 3. Length of Extension Sought. An extension is sought to file Appellee's Brief through June 29, 2015. 4. No Previous Extension Sought by Appellee. Appellee has sought no previous extension of Appellee's briefing deadline. 5. Reason that Extension is Sought. This extension is sought because of the busy trial schedule of counsel for Appellee. Counsel has two appellate briefs which are being handled at the same time which is an unusual event. Counsel's secretary has been out for three weeks due to a severe illness and hospitalization which has placed things generally behind on all fronts. This extension is not sought for delay but to allow due consideration of Appellants' Brief and a detailed response to it. 3 (18705.43065-00384445.DOCX) WHEREFORE, PREMISES CONSIDERED, Appellee requests an extension of the within in which to file Appellee's Brief until June 29, 2015. Respectfull ubmitted, 1V10 ORMA A HALEY UPCHURCH & YATES, LLP By: STEVEN C. HALEY State Bar No. 08741900 207 East Main P.O. Box 1808 Brenham, Texas 77834- :08 Telephone: (979) 83. 664 Telecopier: (979) 830-0913 shaley@moormantate.corn MONTEZ & PATTERSON John H. Patterson, Jr. State Bar No. 24027716 Thornton Plaza 508 Thorton, Suite 4 Cotulla, Texas 78014 Telephone: (830) 483-5191 Telecopier: (830) 483-5192 john@montezandpatterson.com Attorneys for Appellee, GRACE RIVER RANCH, L.L.C. 4 {18705.43065-00384445.DOCX) CERTIFICATE OF SERVICE I, Steven C. Haley, do hereby certify that on the-2-1-61 day of May, 2015, I served a true and correct copy of the foregoing Motion to Extend Time to File Appellee's Brief to the following, deposited in a post-paid, depository under the care and custody of the United States Postal Service, duly addressed to such party at the address stated, by certified mail, return receipt requested, facsimile, e-mail, and/or hand-delivery. Annalyn G. Smith Schmoyer Reinhard, LLP 17806 I-10W, Ste. 400 San Antonio, Texas 78257 E-mail: asmith@ar-11p.com Kimberly S. Keller Keller Stolarczyk PLLC 234 West Bandera Road, No. 120 Boerne, Texas 78006 E-mail: kim@kellsto.com Donato D. Ramos Donato D. Ramos, Jr. Law Offices of Donato D. Ramos 6721 McPherson P.O. Box 452009 Laredo, Texas 78045 donatoramosjr@ddrlex.com STEVEN C. HALEY 5 {18705.43065-00384445DOCX} CERTIFICATE OF CONFERENCE I hereby certify that on May 1$,-20-1-5, nferred with opposing counsel, Kimberly S. Keller, who indicate 'she does not op.ose he foregoing Motion to Extend Time to File Appellee's grief. STEVEN C. HALEY 6 {18705.43065-00384445.DOCX}