ACCEPTED
04-14-00609-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/12/2015 6:00:23 PM
KEITH HOTTLE
CLERK
NO. 04-14-00609
_____________________________________________________________________________
FILED IN
4th COURT
IN THE TEXAS COURT OF APPEALS - FOURTEENTH JUDICIAL OF APPEALS
DISTRICT
SAN ANTONIO, TEXAS
IRMA LEMUS and MANUEL LEMUS, JR., 06/12/2015 6:00:23 PM
Appellants
V. KEITH E. HOTTLE
Clerk
JOHNNY MONTOYA GARZA, JOHN RENE AGUILAR,
LAURA ASHLEY WELLS and JOHNNY B. WELLS, Appellees
On Appeal from Cause No. 2012-CI-00251, 225th Judicial District Court of Bexar County
______________________________________________________________________________
APPELLEE'S MOTION FOR EXTENSION
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COME NOW Appellees, JOHNNY MONTOYA GARZA, JOHN RENE AGUILAR,
LAURA ASHLEY WELLS and JOHNNY B. WELLS, and respectfully request that this
Honorable Court grant an additional five days to file their brief on appeal. In support thereof,
they would show the following:
I. Jurisdiction
This court has jurisdiction to grant an extension of time pursuant to Tex. R. Civ. App. Rule
38.6(d).
Appellees’ brief is due June 12th. Appellants’ redrawn brief was filed on May 11, 2015 as
ordered by the Court after an initial brief was filed April 20, 2015 upon a thirty day extension.
Appellees’ counsel requests such additional time as necessary to complete a competently
prepared brief fully in compliance with the Texas Rules of Appellate Procedure and, being
technologically challenged, to assemble an appendix in pdf format, with appropriate references to
the same.
Appellees would respectfully show that failure to file on this, the due date, was not
deliberate or intentional but the result of inadvertence, mistake and mischance.
WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray for additional
five days to file their brief on appeal, and for such other and further relief to which they may be
justly entitled.
Respectfully submitted,
/s/ Anita J. Anderson
ANITA J. ANDERSON
Texas Bar No. 01165955
LAW OFFICE OF ANITA J. ANDERSON
Conference: 303 West Sunset Suite 103
Correspondence: POB 830722
San Antonio, Texas 78283
Telephone (210) 533-8726
Telecopier (210) 633-0989
ajanderson1111@gmail.com
CERTIFICATE OF SERVICE
A true and correct copy of the above and forgoing has been forwarded by e-service and
facsimile transmission to Ana Laura Hessbrook, attorney of record for Defendants Irma Lemus
and Manuel Lemus, Jr. at 4100 N.W. Loop 410, Suite 105, San Antonio, Texas 78229
hessbrook@sbcglobal.net, (210) 706 -9467 and Sarah Anne Lishman, 310 South St. Mary’s St.,
Suite 845, San Antonio, Texas 78205, sarahanne@jamiegrahamlaw.com (210)308-5669 this 12th
day of June, 2015.
/s/ Anita J. Anderson
ANITA J. ANDERSON
WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray that this
Honorable Court order an extension of time to Appellees for filing of their brief to and for such
further relief to which they may be justly entitled.
Respectfully submitted,
/s/ Anita J. Anderson
ANITA J. ANDERSON
Texas Bar No. 01165955
LAW OFFICE OF ANITA J. ANDERSON
Conference: 303 West Sunset Suite 103
Correspondence: POB 830722
San Antonio, Texas 78283
Telephone (210) 533-8726
Telecopier (210) 633-0989
ajanderson1111@gmail.com
CERTIFICATE OF SERVICE
A true and correct copy of the above and forgoing has been forwarded by e-service and
facsimile transmission to Ana Laura Hessbrook, attorney of record for Defendants Irma Lemus
and Manuel Lemus, Jr. at 4100 N.W. Loop 410, Suite 105, San Antonio, Texas 78229
hessbrook@sbcglobal.net, (210) 706 -9467 and Sarah Anne Lishman, 310 South St. Mary’s St.,
Suite 845, San Antonio, Texas 78205, sarahanne@jamiegrahamlaw.com (210)308-5669 this 12th
day of June, 2015.
/s/ Anita J. Anderson
ANITA J. ANDERSON