ACCEPTED
04-14-00551-cv
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
10/22/2015 10:58:11 PM
KEITH HOTTLE
CLERK
NO. 04-14-00551-CV
FILED IN
IN THE COURT OF APPEALS 4th COURT OF APPEALS
FOR THE SAN ANTONIO, TEXAS
10/22/2015 10:58:11 PM
FOURTH JUDICIAL DISTRICT OF TEXAS
KEITH E. HOTTLE
SAN ANTONIO, TEXAS Clerk
PABLO SOLIZ § APPELLANT
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V. §
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STATE OF TEXAS § APPELLEE
APPEAL FROM 79th JUDICIAL DISTRICT COURT
BROOKS COUNTY, TEXAS
TRIAL COURT NO. 14-02-16542-CV
________________________________________________________________
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE
MOTION FOR RECONSIDERATION EN BANC
Rick Soliz
Attorney at Law
Texas Bar Number 00785013
P.O. Box 4051
Houston, Texas 77210
713-228-1900
Counsel Pro Bono
________________________________________________________________
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TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes, Pablo Soliz, Appellant in the above entitled and numbered
cause, by and through his pro bono attorney of record, Rick Soliz, and submits
this first Motion for Extension of Time to file Appellant's Motion for
Reconsideration En Banc until November 5, 2015. For good cause, Appellant
shows as follows.
1. This Court issued its opinion on July 22, 2015. On September 8,
2015, Appellant’s motion for rehearing was filed and it was overruled on
September 22, 2015. This motion may be filed by October 22, 2015. This is
Appellant's first request for an extension of time to file Appellant's Motion for
Reconsideration En Banc.
2. In the last thirty days, Appellant's counsel has had a heavy
workload and out of town court business several times.
3. Furthermore, Appellant’s counsel, in the last 2 weeks, has attended
a continuing education seminar and concentrated on extensive State Bar of
Texas committee business. Counsel is also in the process of relocating his
primary office space to another location.
4. The failure to file the motion for reconsideration en banc within the
specified period allowed was not deliberate or intentional. Appellant is
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requesting an extension of time until November 5, 2015 and will not seek further
extensions.
5. This Motion is not made for delay, but to see that justice is done.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the
deadline for filing of Appellant's motion for reconsideration en banc be extended
to November 5, 2015 or any date the court sees fit.
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the attached and foregoing
document is served on opposing counsel.
Respectfully submitted,
/S/
/s/ Rick Soliz
T.B.N. 00785013
P.O. Box 4051
Houston, Texas 77210
713-228-1900
Pro Bono Attorney for Appellant
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