ACCEPTED
04-15-00074-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
11/2/2015 9:03:24 AM
KEITH HOTTLE
CLERK
CAUSE NO. 04-15-00074-CV
FILED IN
4th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE FOURTHSANCOURT
ANTONIO, TEXAS
OF APPEALS DISTRICT OF TEXAS, SAN ANTONIO, TEXAS
11/2/2015 9:03:24 AM
KEITH E. HOTTLE
Clerk
STACEY SCOTT,
Appellant
vs.
LARRY FURROW AND KELLER WILLIAMS LEGACY GROUP,
Appellees
ON APPEAL FROM THE 25™ JUDICIAL
DISTRICT COURT OF GUADALUPE COUNTY, TEXAS
CAUSE NO. 13-1125-CV-A
UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE BRIEF OF APPELLEES
TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS OF
THE STATE OF TEXAS, SAN ANTONIO, TEXAS:
NOW COME LARRY FURROW and KELLER WILLIAMS LEGACY
GROUP, Appellees in this cause, and file this their Unopposed Motion for Extension
of Time to File Brief; and in support thereof would respectfully show this Honorable
Court as follows: .
I.
Appellee's Brief is currently due on November 2, 2015. Appellant was
previously granted several unopposed extensions in which to file her brief. This is the
first request for an extension of the deadline for filing Appellees' Brief herein.
II.
In addition to the undersigned counsel's normally heavy trial and appellate
workload, counsel is involved in complex litigation pending in Cause No. 5-15-CV-
0284-RP in the Western District of Texas styled Nvision Biomedical Technologies,
LLC vs. JALEX Medical, LLC
III.
By reason of the foregoing, Appellees respectfully request of this Honorable
Court a 21-day extension until Monday, November 23, 2015 in which to file the Brief
ofAppellees in this matter. This extension of time will not work a hardship upon any
party, and will facilitate the presentation of briefs sufficient to apprise the Court of the
pertinent facts and law governing the issues at bar and to assist this Honorable Court
in a correct and complete resolution thereof.
IV.
Pursuant to Rule 10.1(a)(5), Tex. R. App. P., the undersigned counsel for
Appellees has conferred with Mr. Frederick Junldn, counsel for Appellant, who stated
that he is not opposed to this motion.
This extension is not sought for delay only, but so that justice may be done.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray that
this Unopposed Motion for Extension to Time to File Brief be granted; and for such
other and further relief, at law or in equity, to which Appellees might show themselves
justly entitled.
Respectfully submitted,
THORNTON, BIECHLIN, SEGRATO,
REYNOLDS & GUERRA, L.C.
100 N.E. Loop 410, Suite 500
San Antonio, TX 78216
Telephone: 210/342-5555; 210/525-0666 fax
By: sA^auehan E. Waters
Vaughan E. Waters
State Bar No. 20916700
ATTORNEYS FOR APPELLEES
CERTIFICATE OF SERVICE
A true and correct copy of the above and foregoing instrument has been
forwarded to the undersigned party on the 2nd day of November, 2015.
Via e-service
Mr. Frederick Junldn
Andrews Kurth LLP
600 Travis St, Suite 4200
Houston'/TX 77002
Attorneys for Appellant.
sA^aughan E. Waters
Vaughan E. Waters