ACCEPTED
04-14-00667-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
7/7/2015 10:52:06 AM
KEITH HOTTLE
CLERK
CAUSE NUMBER 04-14-667-CV
_____________________________ FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
RAMIRO AND EDNA RAMOS AND 07/7/2015 10:52:06 AM
FEDERICO SALAZAR, JR., APPELLANTS KEITH E. HOTTLE
Clerk
V.
THE UNKNOWN HEIRS OF
TOMASA GONZALEZ AND
NARCISO GONZALEZ, APPELLEES
____________________________
IN THE FOURTH COURT OF APPEALS
SAN ANTONIO TEXAS
_____________________________
ON APPEAL FROM THE
st
381 JUDICIAL DISTRICT COURT
TRIAL CAUSE NO. DC-09-559
HON. J. MANUEL BANALES,
PRESIDING JUDGE
____________________________
THE APPELLEES’ SECOND
MOTION FOR EXTENSION OF TIME
TO FILE THEIR COMPANION BRIEF
________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
The Appellees again motion this Court for an extension of time to file their
companion Brief and, in support hereof, show the following:
HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION2.mot Page 1 of 4
I. DEADLINE
The Appellees were granted an extension of time to file their Brief to on or
before 5:00 PM, 3 July. As of the moment this Second Motion was filed, no
submission date has been scheduled.
II. LENGTH OF TIME SOUGHT FOR
A SECOND EXTENSION
The undersigned motions for an Order of this Court allowing for an extension
of time to file the Appellees’ companion Brief to the date it is marked received.
III. THE FACTS IN SUPPORT OF THIS MOTION
He was unable to timely-file the Appellees’ Brief because the repairs he
thought were being done to allow him access to his laptop’s content took longer than
he was told they would, and when he finally got the laptop back, some of the same
problems he encountered the first time it began malfunctioning reoccurred.
Therefore, he had to return it for more work, and it was only by 10:00 AM,
Monday 6 July that he was able to start again on his penultimate draft to draft his
final draft, which is filed along with this Motion.
Finally, the undersigned had a major breakdown of his car, which caused the
loss of more valuable time.
HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION2.mot Page 2 of 4
IV. NUMBER OF EXTENSIONS.
This is the Appellees’ second Motion, and will be the last because their Brief is
also being filed.
V. CONFERENCE WITH THE
APPELLANTS’ APPELLATE COUNSEL
The undersigned did not confer with Mr. Miller about his position respecting
this Second Motion because he decided to concentrate on getting the companion Brief
filed with this Motion.
Based on the foregoing facts, the undersigned motions this Court for an Order
allowing for an extension of time to file the Appellees’ companion Brief on the date it
is received.
Respectfully Submitted By:
____ / JOHN A. OLSON/ ________
JOHN A. OLSON
Tex. Bar No. 15274750
20634 Creek River
San Antonio TX 78259-2084
210-307-0336 Office
210-858-6780 Fax
jaolson_ccda@yahoo.com
HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION2.mot Page 3 of 4
CERTIFICATE OF SERVICE
I delivered a copy of this SECOND MOTION, etc., to the Law Offices of Mr. Keith
P. Miller and Ms. Megan C. Kucera, the Appellants’ Attorneys, on 7 July 2015.
___ /JOHN A. OLSON/ ________
JOHN A. OLSON
jaolson_ccda@yahoo.com
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