ACCEPTED
04-17-00409-CV
*,*t-_. _. | FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
9/25/2017 10:21 AM
NO. 04-17-00409-CV
FILED IN
IN THE 4th COURT OF APPEALS
FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS
SAN ANTONIO, TEXAS 09/25/2017 10:21:34 AM
KEITH E. HOTTLE
CLERK
Samuel Dodson
Appellant
VS.
Benito Munoz d/b/a B M Transport, Erik Munoz, and David Henry Owens
Appellees
And
American Interstate Insurance Company
On appeal from Cause No. 16-0367-CV
25th Judicial District Court of Guadalupe County, Texas
Honorable William D. Old Ill., Presiding Judge
UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE BRIEF OF APPELLEE
Samuel Dodson (((Appellant") respectfully moves this Court for an
unopposed extension of time to flle Appellant,s brief in the above-styled appeal as
follows:
1. This is an appeal from the Trial Court,s take nothing judgment in favor
of Appellees Benito Munoz d/b/a B M Transport, Erik Munoz, and David Henry
Owens and against Appellant. Appellant timely flled his notice of appeal.
2. Specifically) Appellant respectfully requests that the Court extend the cuITent
deadline for filing Appellant,s brief by 30 days from October 2, 2017 to November 1 ,
2017 because of scheduling conflicts with the current briefing SChedule. TEX. R.
APP. P. 38.6(d). Appellant,s counsel has a trial setting on October 2, 2017 in Nueces
County Court at Law No. 3.
3. This is Appellant,s first request for an extension Of time tO flle Appellant,s
brief'
4. Appellant requests this extension in the interests of justice and faimess and
not because of any failure of Appellant or his counsel to comply with the Texas
Rules of Appellate Procedure. Submission of this case will not be unduly delayed by
the granting of this request.
5. Appellee has agreed with this requested relief.
THEREFORE, Appellant respectfully prays the Court grant his extension of
time to flle Appellant,s brief, through and including November 1, 2017, and grant
him all such other and further relief as this Court deems just.
Respectfully submitted,
State BarNo. 08124100
521 Starr Street
2
Corpus Christi, Texas, 78401 I
Telephone: (361) 985-0600
Fax: (361) 985-0601
Email :bgonzalez-svc@tjhlaw. com
Counsel for Appellant Samuel Dodson
CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with counsel for Appellees, Benito Munoz
d/b/a B M Transport, Erik Munoz, and David Henry Owens; and counsel for
American Interstate Insurance Company and was advised by email that they do
not oppose this requested extension of time.
3
1 a I +
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of this Motion on the-
counsel of record listed below via e-flling on this 25th day of September 20 17.
Dan Pozza
Pozza & Whyte, PLLC
239 East Commerce Street
San Antonio, TX 78205
Phone:(210) 287-9068
Fax: (210) 222-8477
Lany J. Goldman
Goldman & Associates
10100 Reunion Place, Suite 800
Sam Antonio, Texas 78216
Phone: (210) 340-9800
Fax: (210) 340-9888
ATTORI\unYS FOR AppELLEES
Brent L. Watkins
Krystal Elaine RIley
SKELTON SLUSRER BARNIIILL WATKINS WELLS, PLLC
1616 S. Chestnut St.
Lufkin, Texas 7590 1
Phone: (936) 632-2300
Fax: (936) 632-6545
ATTORNEYS FOR AnfflRICAN INTERSTATE INSURANCE CoMPAFIV