ACCEPTED
04-15-00392-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
12/21/2015 12:19:48 PM
KEITH HOTTLE
CLERK
NO. 04-15-00392—CV
IN THE FOURTH COURT OF APPEALS
FILED IN
SAN ANTONIO, TEXAS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
12/21/15 12:19:48 PM
KEITH E. HOTTLE
Clerk
JOYCE ANN SARRO,
Appellant,
V.
MICHAEL A. SARRO,
Appellee.
FIRST UNOPPOSED MOTION FOR EXTENSION OF TINIE
TO FILE APPELLEE’S BRIEF
Rachel S. Sadovsky
Cordell & Cordell, P.C.
1010] Reunion Place, Suite 250
San Antonio, Texas 78216
Tel: (210) 812-3400
Fax: (210)812-3401
rsadovsky@corde1llaw.com
SBN: 24081315
Counsel for Appellee Michael A. Sarro
Cause No. 04-15-00392-CV
SARRO V. SARRO
Motionfor Extension of Time to File Brief — ad
Page 1
TO THE HONORABLE FOURTH COURT OF APPEALS:
Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellee, Michael A.
Sarro, files this Unopposed First Motion to Extend Time to File Appel1ee’s Brief.
Appel1ee’s opening brief is currently due on December 21, 2015.
Counsel for Appellee requests a 30-day extension of time to file its brief,
making the brief due on January 20, 2016. This is the first request for extension of
time to file the reply brief.
Counsel for Appellee relies on the following reasons, in addition to the
routine matters that counsel must attend to in daily practice, to explain the need for
the requested extension:
1. Counsel for Appellee has had a vacation planned since mid-year and
has had a vacation letter on file with the courts since November of this
year, attached hereto as Exhibit A; and
2. Counsel for Appellee has already provided counsel for Appellant two
extensions of time to file their brief and counsel for Appellant has
indicated that he would not oppose the extension.
Counsel for Appellee seeks this extension of time to be able to prepare a
cogent and succinct brief to aid this Court in its analysis of the issues presented.
Cause No. 04-15-00392—CV
SARRO V SARRO
Motion for Extension of Time to File Brief — ad
Page 2
This request is not sought for delay but so that justice may be done.
The undersigned has conferred with opposing counsel, and he has indicated
that his client does not oppose this motion.
All facts recited in this motion are within the personal knowledge of the
counsel signing this motion, therefore no Verification is necessary under Rule of
Appellate Procedure 10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellee requests that this Court grant this
Unopposed First Motion to Extend Time to File Appellee’s Brief and extend the
Deadline for Filing the Appellee’s Brief up to and including January 20, 2016.
Appellee prays for all other relief to which he may be entitled.
Respectfully submitted,
llama J M
Rachel S. Sadovsky
Cordell & Cordell, P.C.
10101 Reunion Place, Suite 250
San Antonio, Texas 78216
Tel: (210)812-3400
Fax: (210) 812-3401
rsadovsky@cordelllaw.com
SBN: 24081315
Counsel for Appellee Michael A. Sarro
Cause No. 0445-00392-CV
SARRO V. SARRO
Motion for Extension of Time to File Brief — ad
Page 3
CERTIFICATE OF CONFERENCE
I certify that I conferred with counsel for Appellant regarding this motion and that
Appellee/Appellant is not opposed to this motion.
Rachel S. Sadovsky K)
Counsel for Appellee Michael A. Sarro
CERTIFICATE OF SERVICE
I certify that on December 21, 2015, I served this motion through electronic service
through an electronic filing manager and by fax to R. Robert Willmann; Attorney
at Law; P.O. Box 460167, San Antonio, Texas 78246; (361) 552-4305
(willaw@prismnet.com) — Attorney for Appellant Joyce Ann Sarro.
Rachel S. Sadovsky U
Counsel for Appellee Michael A. Sarro
Cause No. 04-15-00392-CV
SARRO V SARRO
Motion for Extension of Time to File Brief - ad
Page 4
_'
FILED
3
11/23/2015 11:53:01 AM
;
Donna Kay McKinney
Bexar County District Clerk
C Cordell Cordell
-.
Accepted By: Cynthia Flores
1'
A Domestic Litigation Firm
A Partner Men Can COUfli' OI’l.‘3
RACHEL S. SADOVSKY
ASSOCIATE ATTORNEY
rsadovsky@cordelllaw.coin
November 17, 2015
Civil Jury Setting Clerk CivilNon—Ju1y Setting Clerk
Bexar County Courthouse Bexar County Courthouse
100 Dolorosa Street 100 Dolorosa Street
San Antonio, Texas 78205 San Antonio, Texas 78205
Bexar County District Clerk Guadalupe County District Clerk
Paul Elizondo Tower Guadalupe County Courthouse
101 W. Nueva, Suite 217 101 E. Court St., Suite 308
San Antonio, Texas 78205 Seguin, Texas 78155
Bandera County District Clerk Wilson County District Clerk
P. O. Box 2688 PO. Box 812
Bandera, Texas 78003 Floresville, Texas 78114
Kerr County District Clerk Kendall County District Clerk
Kerr County Courthouse Kendall County Courthouse
700 Main Street 201 E. San Antonio Street, Ste. 201
Kerrville, Texas 78028 Boeme, Texas 78006
Karnes County District Clerk Uvalde County District Clerk
210 W. Calvert, Suite 180 Courthouse Plaza, Box 15
Kames City, Texas 78118 Uvalde, Texas 78801
Gillespie County District Clerk Atascosa County District Clerk
101 West Main Street, Atascosa County Courthouse
Mail Unit 3, Room 204 1 Courthouse Circle Drive, Suite 4-B
Fredericksburg, Texas 78624-3700 Jourdanton, Texas 78026
Bee County District Clerk Medina County District Clerk
P. O. Box 666 1100 16th Street, Room 209
Beeville, Texas 78104 Hondo, Texas 78861
Maverick County District Clerk Cameron County District Clerk
500 Quarry Street, Suite 5 Cameron County Courthouse
Eagle Pass, Texas 78852 Judicial Building, 3rd Floor
974 East Harrison Street
Brownsville, Texas 78520
Phone: 210.812.3400 10101 Reunion Place MansDivon:e.com -
I3adsDivovce.com - Cordeilcordeiimom
Fax‘ 210.812.3401 Suite 250 Cordell & Cordell, RC.
(
Cordell Law. LLP
Toll Free: 866,323.7529 San Antonio, TX 78216
Re: Vacation Notice
Dear Sir and/or Madarns:
This serve as notice that I will be out of the office on vacation,
letter shall
firm business
or involved in State Bar related activities during the following periods:
December 21, 2015 to December 30, 2015
I would appreciate your assistance in not scheduling any court settings, trials, or
otherwise for me during this time period.
Thank you for your cooperation and professional courtesies.
Best regards,
CORDELL & CoRDELL,,P.C.
, >4
~~
_
RACHEL s. SADOVSKY
Texas State Bar No. 240813
RSS:jh
co: Opposing Counsel via facsimile
MensDivorce.com -
DadsDivorce.com - CordellCordeI|.corn
Cordell & Cordell, PC|
Cordell Law. LLP