ACCEPTED
04-14-00564-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/13/2015 3:16:10 PM
KEITH HOTTLE
NO. 04-14-00564-CV
CLERK
IN THE COURT OF APPEALS
FOURTH DISTRICT OF TEXAS FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS
4/13/2015 3:16:10 PM
KEITH E. HOTTLE
IN THE ESTATE OF WADE R. BEDELL, JR. DECEASEDClerk
APPELLEE’S UNOPPOSED SECOND
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE FOURTH COURT OF APPEALS:
Appellee Robyn Joan Zalewa asks the Court to extend the time for
filing her brief to and including April 23, 2015, and in support of this
motion shows:
Date of Judgment, Number and Style of Case
1. This is an appeal from a final judgment signed on April 1, 2014,
by the Honorable Tom Rickhoff, Probate Court No. 2, Bexar County, Texas,
in Cause No. 2013-PC-0636, styled In the Estate of Wade R. Bedell, Jr.,
Deceased.
Perfection of Appeal
2. Appellant Deborah Bedell filed her notice of appeal with this
Court on August 7, 2014.
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 1
Record
3. The clerk’s record was filed with this Court on August 7, 2014,
with subsequent supplemental clerk’s records that were filed on August 27,
2014, September 9, 2014, October 9, 2014, December 31, 2014, and January
12, 2015. The reporter’s record was filed with this Court on August 14,
2014, and a supplemental reporter’s record filed on February 18, 2015.
Current Deadline
4. Appellant filed her amended brief on February 10, 2015. After
having received one previous extension, Appellee’s brief is due on April 13,
2015.
Length of Extension Sought
5. Appellant requests a 10-day extension to April 23, 2015.
Facts Reasonably Explaining Need for Extension
During the last thirty (30) days, the undersigned attorney who has the
primary responsibility to prepare Appellee’s Brief, has been involved in the
following matters, which have hampered his ability to prepare Appellant’s
Brief, as follows:
• Preparation of appellant’s reply brief in Cause No. 04-14-00903-CV,
Lightning Oil Company v. Anadarko E&P Onshore LLC fka
Anadarko E&P Company; Fourth Court of Appeals, San Antonio,
Texas;
• Preparation of response to petition for writ of mandamus in Cause
No. 15-0109; In re Gilbert L. Mathews and Lucifer Lighting
Company; Supreme Court of Texas, Austin, Texas;
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 2
• Preparation of post-trial motions and briefs in Cause No. 29842;
Knighthawk, LLC, Series G v. B&P Development and Chad H. Foster,
Jr., 83rd Judicial District Court, Val Verde County, Texas; and
• Preparation of petitioner’s brief on the merits in Cause No. 14-0223;
Methodist Healthcare System of San Antonio, LTd., LLP dba
Northeast Methodist Hospital v. Thomas Dewey; Supreme Court of
Texas, Austin, Texas.
Second Request for Extension
6. This is the second request for an extension of time to file
Appellee’s brief.
Request for Relief
7. For all these reasons, Appellee Robyn Joan Zalewa respectfully
asks this Court to grant this motion and to extend the date for filing her
brief for a period of 10 days, to April 23, 2015.
Respectfully submitted,
/s/ Robinson C. Ramsey
ROBINSON C. RAMSEY
State Bar No. 16523700
Email: rramsey@langleybanack.com
JAMES W. CARTER, IV
State Bar No. 24006333
Email: jcarter@langleybanack.com
LANGLEY & BANACK, INC.
Trinity Plaza II, Suite 900
745 E. Mulberry Avenue
San Antonio, Texas 78212
Telephone: 210. 736.6600
Telecopier: 210. 735.6889
ATTORNEYS FOR APPELLEE
ROBYN ZALEWA
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 3
CERTIFICATE OF CONFERENCE
Appellee’s attorney has conferred with Appellant’s counsel, John
Wennermark, who does not oppose this motion.
/s/Robinson C. Ramsey
ROBINSON C. RAMSEY
CERTIFICATE OF SERVICE
A true and correct copy of the foregoing document was served upon
the following counsel for Appellant:
John D. Wennermark
State Bar No. 21177000
Email: johnwennermark@hotmail.com
1924 N. Main Avenue
San Antonio, Texas 78212
Telephone: 210.226.6262
Telecopier: 210.225.1351
on this 13th day of April, 2015.
/s/ Robinson C. Ramsey
ROBINSON C. RAMSEY
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 4