Rafael Montez Da Oca v. Eduardo Gutierrez

ACCEPTED 03-14-00668-CV 4832193 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/9/2015 3:57:50 PM JEFFREY D. KYLE CLERK CASE NO. 03-14-00668-CV COURT OF APPEALS, THIRD DISTRICT OF TEXAS FILED IN ------------------------------------------------------------------AUSTIN,OF 3rd COURT APPEALS TEXAS RAFAEL MONTEZ DE OCA, Appellant 4/9/2015 3:57:50 PM JEFFREY D. KYLE V. Clerk EDUARDO GUTIERREZ, Appellee ----------------------------------------------------------------- APPELLEE’S UNOPPOSED MOTION FOR SECOND EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUDGES OF THIS COURT: Appellee, Eduardo Gutierrez, makes his second request for an extension of time to file his Brief in this cause, and would show: 1. At present, the deadline for the filing of Appellee’s Brief in this cause is April 13, 2015. Appellee requests an extension of time until May 4, 2015 to file his Brief. 2. Appellee requests this extension due to the workload of Appellee’s attorney, especially, an expedited proceeding in Texas Education Agency Docket No. 037-LM-03- 2015, styled Austin I.S.D. v. Monica Evans, a pending administrative hearing for April 20- 22, 2105, and the related expedited discovery deadlines (April 2-8, 2015) and expedited dispositive motion schedule (deadlines the week of April 13, 2015), and pre-trial conference and related deadlines for witness and exhibit list, stipulated facts list, etc. (April 16 or 17, 2015). 3. This request for an extension of time should be granted so that justice may be done, and because no harm or prejudice is or will be suffered by Appellant by granting Page 1 this request. 4. CERTIFICATE OF CONFERENCE: On April 9, 2015, Appellee’s counsel’s office consulted with Appellant’s counsel, Ray Bass, concerning this request, and Mr. Bass does not oppose the request. WHEREFORE, Appellee requests an extension of time until May 4, 2015 to file his Brief, and for such other relief to which Appellant is entitled. pmorin@austin.rr.com ATTORNEY FOR APPELLEE CERTIFICATE OF SERVICE This is to certify that on April 9, 2015, a true and correct copy of the above and foregoing was served on counsel for Appellant set forth below as follows: Via email: raybassattorney@gmail.com Ray Bass 120 W. 8th St. Georgetown, TX 78626 Page 2