Board of Adjustment of the City of San Antonio v. Michael and Theresa Hayes

ACCEPTED
04-15-00021-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
9/28/2015 3:49:46 PM
KEITH HOTTLE
CLERK

No. 04-15-00021-CV

IN THE FOURTH COURT OF APPEALS
FILED IN
at SAN ANTONIO, TEXAS 4th COURT OF APPEALS
----------------------- SAN ANTONIO, TEXAS
BOARD OF ADJUSTMENT OF THE CITY OF SAN ANTONIO 09/28/2015 3:49:46 PM
Respondent - Appellant KEITH E. HOTTLE
v. Clerk
MICHAEL AND THERESA HAYES
Petitioners - Appellees
-----------------------
Trl. Ct. No. 2014-CV-00284; Appeal from the County Court At Law No. 10, Bexar County,
Texas; The Honorable David J. Rodriguez, Presiding

===============================================================
APPELLANT’S FIRST MOTION TO EXTEND TIME
TO FILE APPELLANT’S BRIE REPLY
(UNOPPOSED)
===============================================================

TO THE HONORABLE FOURTH COURT OF APPEALS:

The Board of Adjustment of the City of San Antonio, Appellant, submits its unopposed

Motion for Extension of Time to File Appellant's Brief and in support of this motion states as

follows:

1. Appellant's Reply Brief is due Monday, September 28, 2015.

2. This motion is filed prior to the expiration of this due date.

3. The undersigned has conferred with Appellees’ counsel and he has been informed that the

motion is unopposed.

4. Appellant requests an additional ten (10) days to file its Appellant's Reply Brief,

extending the time to file its Brief to October 8, 2015.

5. No extension to file a reply brief has previously been granted. On eectension had been

granted to file the principal brief.

6. This is not an expedited appeal.
7. The undersigned is responsible for the preparation of Appellant's Reply Brief. Over the

past thirty days, the undersigned has been engaged in the preparation of various motions

and responses on several litigation cases, inclusing Guerra. vs Bellino, et al., Cause # SA-

4-cv-652 (XR), United States District Court, San Antonio, Division. In addition to

providing litigation support in several other cases pending in state and federal courts, the

undersigned counsel was engaged in the submission of the Appellant’s brief in City of

Pearsall vs. Tobias, Fourth Court of Appeals, Cause no. 04-15-00302-CV, that was filed

September 25, 2015.

8. In order for Appellant and its counsel to give the necessary attention to the record and the

preparation of its Reply Brief in this matter, Appellant requests the additional time to file

its Reply 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.

CERTIFICATE OF CONFERENCE

I certify that I conferred with opposing counsel regarding this motion and the motion is

unopposed.

PRAYER

Appellant asks this Court to grant its motion extending the deadline to file its Appellant's

Reply Brief to October 8, 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 of appellate procedure upon Leslie Sara Hyman, PULMAN, CAPPUCCIO,
PULLEN, BENSON &JONES, L.L.P., 2161 NW Military Highway, Suite 400, San Antonio,
Texas 78213, and David L. Earl, 745 East Mulberry, Mailbox 16, San Antonio, Texas 78212 on
September 28, 2015.

/s/ Albert López
Albert López