ACCEPTED
04-15-00272-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/17/2015 3:17:06 PM
KEITH HOTTLE
CLERK
NO. 04-15-00272-CV
FILED IN
4th COURT OF APPEALS
IN THE FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS
SAN ANTONIO, TEXAS 06/17/2015 3:17:06 PM
KEITH E. HOTTLE
Clerk
KYU IM ROBINSON,
APPELLANT,
V.
JESS L. MAYFIELD, TRUSTEE, ET AL.,
APPELLEES.
ON APPEAL FROM THE 131ST JUDICIAL DISTRICT COURT
BEXAR COUNTY, TEXAS
HON. RENEE A. YANTA, JUDGE PRESIDING
APPELLANT’S UNOPPOSED FIRST MOTION
FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
Appellant, Kyu Im Robinson (Robinson), files this Unopposed First Motion for
Extension of Time to File Appellant’s Brief.
1. The deadline for filing Appellant’s Brief is June 25, 2015.
2. This is appellant’s first motion for extension of time to file her brief.
3. Appellant requests an extension of 30 days; that is, an extension of time
to and including July 27, 2015 (the 30th day falls on Saturday, July 25, 2015).
4. Counsel could not prepare Appellant’s Brief by the current due date,
given proper standards of representation, because of her work in the following
matters:
a. During the week of May 25th, counsel conducted the research for,
and prepared, Appellants’ Motion for Rehearing and Appellants’ Motion for En Banc
Reconsideration in Prabhakar Guniganti, et al. v. C & S Components Company, Ltd.;
No. 14-14-00224-CV; in the Fourteenth Court of Appeals, Houston, Texas. Those
motions were filed on June 2, 2015.
b. During the week of June 8th, counsel conducted research to assist
appellants’ counsel in the preparation of Appellants’ Post-Submission Brief in The
Huff Energy Fund, L.P., et al. v.Longview Energy Company; No. 04-12-00630-CV;
in the Fourth Court of Appeals, San Antonio, Texas. That Post-Submission Brief was
filed on June 15, 2015.
5. In addition to the foregoing matters, counsel was out of the office from
June 3, 2015, through June 5, 2015, to attend and to make a presentation for The
University of Texas School of Law 25th Annual Conference on State and Federal
Appeals in Austin, Texas.
6. Counsel would further show that since October, 2014, counsel has had
a family vacation planned for the week of June 22, 2015.
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7. Counsel is a solo practitioner and is solely responsible for the work
necessary to prepare Appellant’s Brief in this case.
PRAYER
For the reasons stated, appellant requests that this Court grant this motion and
extend the time for filing Appellant’s Brief to and including July 27, 2015.
Respectfully submitted,
JOANN STOREY, P.C.
BY: /s/ JoAnn Storey
JoAnn Storey
State Bar No. 19315300
1005 Heights Boulevard
Houston, Texas 77008
Telephone: 713/529-0048
Facsimile: 713/529-2498
Email: storeyj@heightslaw.com
Attorney for appellant, Kyu Im
Robinson
CERTIFICATE OF CONFERENCE
Gay Gueringer, counsel for appellee, William P. Riddick, Individually and as
Trustee of the Wm P. Riddick ) 76 Trust does not oppose this motion. Although the
style of this case includes Jess L. Mayfield, Trustee, as an appellee, Mr. Mayfield is
not a party on appeal.
/s/ JoAnn Storey
JoAnn Storey
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CERTIFICATE OF COMPLIANCE
Relying on the word count function in the word processing software used to
produce this document, I certify that the number of words in this motion is 605.
This motion complies with the typeface requirements of TRAP 9.4(e) because
it uses a conventional typeface no smaller than 14-point (WordPerfect X4 14-point
Times New Roman).
/s/ JoAnn Storey
JoAnn Storey
CERTIFICATE OF SERVICE
On June 17, 2015, I sent a true and correct copy of the foregoing Appellant’s
Unopposed First Motion for Extension of Time to File Appellant’s Brief via EFILE
to the following:
Gay Gueringer
RICHIE & GUERINGER, P.C.
112 E. Pecan St., Suite 1420
San Antonio, Texas 78205
Counsel for appellee, William P. Riddick,
Individually and as Trustee of the
Wm P. Riddick ) 76 Trust
/s/ JoAnn Storey
JoAnn Storey
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