ACCEPTED
04-14-00655-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/20/2015 10:07:33 AM
KEITH HOTTLE
CLERK
NO. 04-14-00655-CV
IVARENE HOSEK AND VICTOR § IN THE FOURTH
FILED IN
HOSEK, § 4th COURT OF APPEALS
§ SAN ANTONIO, TEXAS
Appellants, § 04/20/2015 10:07:33 AM
§ KEITH E. HOTTLE
v. § COURT OF Clerk
APPEALS
§
ROSALE SCOTT, §
§
Appellee. § SAN ANTONIO, TEXAS
APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
Appellee ROSALE SCOTT (“Scott”) hereby requests a seven day extension of the
deadline for filing Appellee’s Brief, as well as the appendix to be submitted with the brief, as
follows:
1. The deadline for Appellee to file her Brief is currently April 21, 2015. Under Rule
10.5(b), Tex. R. App. P., Appellee seeks to extend the deadline by seven days, until April 28,
2015.
2. Counsel for Appellee has conferred with counsel for Appellant and she has indicated that
she does not oppose an extension until April 28, 2015 for Appellee’s brief.
3. This is the second motion for extension sought by Appellee on this brief. Appellee
previously requested a two week extension to file the brief, which was granted. Appellee is now
requesting only one additional week in which to file the brief.
4. This extension is requested due to the workload and commitments of counsel for
Appellee and to provide counsel for Appellee with additional time to work on the brief.
Additionally, Appellee’s counsel’s office has recently experienced computer issues which have
resulted in some delay in the preparation of the brief in this case. Therefore, it is requested that:
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a) The Court grant this unopposed motion for extension to file appellee’s
brief, as well as any appendix, until April 28, 2015; and
b) Appellee have such other relief to which she may be entitled.
BARTON, EAST & CALDWELL, P.L.L.C.
One Riverwalk Place, Suite 1825
700 N. St. Mary’s Street
San Antonio, Texas 78205
Telephone: (210) 225-1655
Facsimile: (210) 225-8999
By: /s/ RAQUEL G. PEREZ
G. WADE CALDWELL
State Bar No. 03621020
Email: gcaldwell@beclaw.com
RAQUEL G. PEREZ
State Bar No. 00784746
Email: rperez@beclaw.com
ATTORNEYS FOR APPELLEE
CERTIFICATE OF CONFERENCE
On or about April 19, 2015, I conferred with Michele Chimene, counsel for Appellant,
regarding the relief requested in this motion. She indicated that she is not opposed to an
extension until April 28, 2015 for the filing of Appellee’s brief.
/s/ RAQUEL G. PEREZ
RAQUEL G. PEREZ
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this document will be served in the manner
indicated below this 20th day of April, 2015 upon the following:
Michele Barber Chimene ___ First Class Mail
The Chimene Law Firm ___ Facsimile
2827 Linkwood Dr. ___ Hand Delivery
Houston, TX 77025-3809 X Electronic Transmission
Email: michelec@airmail.net
Robert J. Ogle ___ First Class Mail
Attorney at Law ___ Facsimile
508 E. San Antonio Street ___ Hand Delivery
Boerne, Texas 78006 X Electronic Transmission
Facsimile: (830) 249-8508
Email: bob@ogleattorney.com
Counsel for Appellants
/s/ RAQUEL G. PEREZ
G. WADE CALDWELL
RAQUEL G. PEREZ
M:\2000\2200 OIL AND GAS CLIENTS\121 Hosek v Scott\4TH COA APPEAL\Pleadings\Appellee's 2nd Motion for Extn to File Brief.docx
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Ivarene and Victor Hosek v. Rosale Scott
Combined Opinion