John A. Lance, Debra L. Lance, F.D. Franks and Helen Franks v. Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray and Butch Townsend

ACCEPTED
04-14-00758-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/3/2015 3:41:37 PM
KEITH HOTTLE
CLERK

NO. 04-14-00758-CV
FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
6/3/2015 3:41:37 PM
In The KEITH E. HOTTLE
Clerk

Fourth Court of Appeals
San Antonio, Texas

John A. Lance, Debra L. Lance, F. D. Franks and
Helen Franks, Appellants
v.

Judith and Terry Robinson, Gary and Brenda Fest, Virginia
Gray, Butch Townsend, and Bexar-Medina-Atascosa Counties
Water Control and Improvement District No. 1, Appellees

SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE'S BRIEF (UNOPPOSED)

\Vater Control

District No. 1 (BMA) file their second for extension of time to file

s Appellee's IS on June 8, 2015. R. P.
38.6. This motion is filed prior to the due date. Appellant's counsel does not

oppose this motion.

Appellee needs additional time to prepare and file their brief. Appellee asks

the Court to grant an extension of time to Wednesday, July 8, 2015, an extension

of30 days.

Appellee's counsel was preparing for and arguing a Motion for Summary

Judgment held on May 13, 2015, in the matter of WPS, LLC A Texas Limited

Liability Company D/B/A Federal Management Solutions v. Mission Valley Mill

Holding, LLC, Cause No. 2013CVA0461, County Court at Law, Comal County,

Texas. Additionally, Appellee's counsel will be preparing for mediation tentatively

set on June 8, 2015, regarding the same matter.

Furthermore, Appellee's counsel sustained a back injury on May 25, 2015,

and a subsequent aggravation on May 27, 2015, which caused Appellee's counsel

to miss virtually the entire week of work May 25,2015 through May 29, 2015.

PRAYER

the

or
 PRespectfully submitted,

GOSTOMSKI & HECKER, P.C.
607 Urban Loop
San Antonio, Texas 78204-3117
(21 0) 222-9529 Telephone
(210) 222-9540 Facsimile
ed@ghlawyers.net

BY:
EDWARD T. HECKER
State Bar No. 00787668
PETER B. GOSTOMSKI
State Bar No. 00787571

ATTORNEYS FOR BMA

CERTIFICATE OF SERVICE

I certify that on June 2015, a true and correct copy of this document was served on
the following counsel of record:

Dan Pozza VIA EMAIL: danpozza@yahoo.com
Law Office of Dan Pozza
239 E. Commerce Street
San Antonio, TX 78205
(21 0) 226-8888 Telephone
(210) 224-6373 Facsimile

Stephen B. Rogers VIA EMAIL: steve@Togersmoorelaw.com
ROGERS & MOORE PLLC