ACCEPTED
04-16-00786-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
9/25/2017 2:27 PM
NO. 04-16-00786
FILED IN
IN THE 4th COURT OF APPEALS
FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS
SAN ANTONIO, TEXAS 09/25/2017 2:27:41 PM
KEITH E. HOTTLE
CLERK
ANTHONY MOORE AND JOANN MOORE,
Appellant
v.
DAVID SUBIA,
Appellee
__________________________________________________________________
On Appeal from the County Court at Law, Bexar County, Texas
APPELLEE’S OPPOSED MOTION FOR EXTENSION OF TIME
TO FILE HIS BRIEF
TO THE HONORABLE FOURTH COURT OF APPEALS:
APPELLEE, DAVID SUBIA (“Appellee”), respectfully present his Motion
for Extension of Time to file His Brief, and would respectfully show the Court as
follows:
I.
On August 21, 2017, Appellants filed their Amended Brief. Appellee’s
Brief was due on September 20, 2017. Appellees request an extension of time to
file their brief for the following reasons:
The undersigned attended numerous hearings during the week of August 21,
2017 to August 25, 2017 in child custody and real estate matters;
The undersigned participated in a two-day mediation on August 30, 2017
and September 1, 2017;
The undersigned worked on a petition for review to the Texas Supreme
Court during the week of September 5, 2017 to September 8, 2017;
The undersigned’s office was closed for Labor Day on September 4, 2017;
and
The length of Appellants’ Brief requires additional time to respond.
II.
Appellee asks this Court to extend the time to file their Brief for thirty days
up to and including October 20, 2017. Appellants have been granted numerous
extensions of time in the past.
III.
This motion is not brought for purposes of delay but solely that justice may
be served.
WHEREFORE, PREMISES CONSIDERED, APPELLEE prays that he be
given an additional thirty (30) days to respond to Appellants’ Brief. Appellee
prays for such other relief to which he may be entitled consistent with this Court’s
ruling.
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Respectfully submitted,
/s/ Christopher J. Deeves
CHRISTOPHER J. DEEVES
State Bar No. 00790575
THE LAW OFFICE OF
CHRISTOPHER DEEVES, P.C.
1370 Pantheon Way, Suite 110
San Antonio, Texas 78232
(210) 445-8807
(210) 501-0915 (fax)
e-mail: chrisdeeves@att.net
ATTORNEY FOR
APPELLEE
DAVID SUBIA
CERTIFICATE OF CONFERENCE
On September 20, 2017, Appellee’s counsel called pro se Appellant,
Anthony Moore, who refused to discuss this matter without a submission in
writing. A proposed motion was sent to him. Pro se Appellant then filed an
opposition to this motion without ever receiving the proposed motion or discussing
it. This motion is therefore opposed.
/s/ Christopher J. Deeves
CHRISTOPHER J. DEEVES
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CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the above and foregoing
document was served as indicated to the following counsel of record listed below
on September 25, 2017:
Via Priority Mail
Anthony Moore
Joann Moore
P.O. Box 340096
San Antonio, Texas 78234
/s/ Christopher J. Deeves
CHRISTOPHER J. DEEVES
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