ACCEPTED
04-15-00070-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
7/20/2015 2:34:08 PM
KEITH HOTTLE
CLERK
No. 04-15-00070-CV
FILED IN
In The Fourth Court Of Appeals 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
San Antonio, Texas 7/20/2015 2:34:08 PM
KEITH E. HOTTLE
Clerk
SKYLINE EMS, INC. AND JUAN “JOHNNY” CORDERO
Appellants,
v.
AR CONCEPTS, INC.
Appellee.
ON APPEAL FROM THE 224th DISTRICT COURT, Bexar COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2014CI15618
APPELLEE’S UNOPPOSED FIRST MOTION TO EXTEND TIME TO
FILE APPELLEE’S BRIEF
The Cavazos Law Firm, P.C.
David H. Cavazos IV
Texas Bar No. 24031923
P.O. Box 1353
Boerne, Texas 78006
Telephone: (915) 227-7515
Facsimile: (915) 808-2558
A/R Concepts, Inc.
Identity of Parties and Counsel
Appellants/Defendants: Defendants/Appellants’ Appellate
Counsel:
RYAN LAW FIRM, LLP
Doug Sigel
Texas Bar No. 18347650
100 Congress Avenue, Suite 950
Austin, Texas 78701
Telephone: (512) 459-6600
Facsimile: (512) 459-6601
Doug.Sigel@ryanlawllp.com
Appellee/Plaintiff: Plaintiff/Appellee’s Appellate Counsel:
David Henry Cavazos IV
The Cavazos Law Firm PC
P.O. Box 1353
Boerne, Texas 78006
Telephone: (915) 227-7515
Facsimile: (915) 808-2558
cavazoslaw@aol.com
TO THE HONORABLE FOURTH COURT OF APPEALS:
Pursuant to Tex. R. App. P. 10.1 and 38.6(d), the Appellee, A/R
Concepts, Inc., files this Unopposed First Motion to Extend Time to file
Appellee's brief.
The Appellee's Brief was due on July 17, 2015.
Counsel for Appellee requests a 30-day extension of time to file
its Appellee's Brief, making the brief due on August 17, 2015. This is the first
request for extension of time to file the Appellee's Brief.
Counsel for Appellee relies on the following reason, in addition to the
routine matters that counsel must attend to in daily practice, to explain the need
for the requested extension:
• The undersigned counsel was in the hospital for five days in June, which
caused a delay in calendar scheduling of events, deadlines and hearing dates.
• The undersigned counsel is still in the process of re-scheduling events,
deadlines and hearing dates on his calendar.
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.
This request is not sought for delay but so that justice may be done.
The undersigned conferred with Doug Sigel and Katherine Quiniola of the Ryan
Law Firm, counsel for the Defendants/Appellants, and was able to obtain
confirmation that opposing counsel was not opposed to 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 Texas 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 August 17, 2015.
Appellee requests all other relief to which it may be entitled.
Respectfully submitted,
The Cavazos Law Firm, P.C.
/s/ David H. Cavazos IV
David Henry Cavazos IV
Texas Bar No. 24031923
P.O. Box 1353
Boerne, Texas 78006
Telephone: (915) 227-7515
Facsimile: (915) 808-2558
cavazoslaw@aol.com
Attorney For Appellee
A/R Concepts, Inc.
CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. P. 10.1(5), I certify that the undersigned counsel
conferred with opposing counsel, Doug Sigel and Katherine Quiniola, The Ryan Law
Firm, LLP. on July 20, 2015, and was unable to obtain confirmation from attorney
Katherine Quinola, associate counsel for Appellants, that counsel for Appellants
was not opposed to the filing of this motion and the relief requested in said motion.
/s/ David H. Cavazos IV
David H. Cavazos IV
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing Appellee’s Unopposed First Motion to
Extend Time to File Appellee’s Brief was served on Appellant, Skyline EMS., Inc.
and Juan “Johnny” Cordero, through counsel of record, Doug Sigel, The Ryan
Law Firm, LLP, 100 Congress Avenue, Suite 950, Austin, Texas 78701, by
electronic mail and electronic service on July 20, 2015.
/s/ David H. Cavazos IV
David H. Cavazos IV
Skyline EMS Inc. and Juan "Johnny" Cordero v. AR Concepts Inc.
Combined Opinion