City of Pearsall v. Robert Tobias

ACCEPTED 04-15-00302-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 8/24/2015 1:12:28 PM KEITH HOTTLE CLERK No. 04-15-00302-CV IN THE FOURTH COURT OF APPEALS FILED IN at SAN ANTONIO, TEXAS 4th COURT OF APPEALS ----------------------- SAN ANTONIO, TEXAS CITY OF PEARSALL 8/24/2015 1:12:28 PM Defendant - Appellant KEITH E. HOTTLE v. Clerk ROBERT TOBIAS Plaintiffs - Appellee ----------------------- Trl. Ct. No. 13-10-00414 CVF; Appeal from the 218th Judicial District Court, Frio County, Texas; the Honorable Donna S. Rayes, Presiding =============================================================== APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF (UNOPPOSED) =============================================================== TO THE HONORABLE FOURTH COURT OF APPEALS: The City of Pearsall, Appellant, submits its Unopposed First Motion for Extension of Time to File Appellant's Brief and in support of this motion states as follows: 1. Appellant's Brief is due August 26, 2015. 2. This motion is filed prior to the expiration of this due date. 3. The undersigned has conferred with Appellee’s counsel and he has informed counsel that the motion is onopposed. 4. Appellant requests an additional thirty (30) days to file its Appellant's Brief, extending the time to file its Brief to September 25, 2015. 5. No extension has previously been granted. 6. This is not an expedited appeal. 7. The undersigned is responsible for the preparation of Appellant's Brief. Over the past thirty days, the undersigned has been engaged in the preparation of various motions and responses on several litigation cases and in preparation for a Petition for Review before the Supreme Court in the case of Board of Adjustment for City of San Antonio & Sarosh Management, Llc, D/b/a A-z Food Mart vs. East Central Independent School District, No. 15-0469, that was due August 21, 2015. 8. In order for Appellant and its counsel to give the necessary attention to the record and the preparation of its Brief in this matter, Appellant requests the additional time to file its Brief. Appellant believes that an adequate and proper brief can be filed within the time requested. 8. This extension request is not filed for purposes of delay. PRAYER Appellant asks this Court to grant its motion extending the deadline to file its Appellant's Brief to September 25, 2015. Respectfully submitted, LAW OFFICES OF ALBERT LÓPEZ 14310 Northbrook Dr., Suite 200 San Antonio, Texas 78232 Telephone: (210) 404-1983 Fax: (210) 404-1990 By: /s/ Albert López ALBERT LÓPEZ State Bar No. 12562350 alopezoffice@gmail.com ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument was served pursuant to the rules upon Reid E. Meyers, Attorney at Law, 11118 Wurzbach Rd., San Antonio, TX 78230 on August 24, 2015. /s/ Albert López Albert López