Ramiro and Edna Ramos, and Federico Salazar, Jr. v. the Unknown Heirs of Tomasa Gonzalez and Narciso Gonzalez

ACCEPTED
04-14-00667-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
8/19/2015 10:48:29 AM
KEITH HOTTLE
CLERK

CAUSE NUMBER 04-14-667-CV
_____________________________ FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
RAMIRO AND EDNA RAMOS AND 08/19/2015 10:48:29 AM
FEDERICO SALAZAR, JR., APPELLANTS KEITH E. HOTTLE
Clerk
V.

THE UNKNOWN HEIRS OF
TOMASA GONZALEZ AND
NARCISO GONZALEZ, APPELLEES
____________________________

IN THE FOURTH COURT OF APPEALS
SAN ANTONIO TEXAS
_____________________________

ON APPEAL FROM THE
st
381 JUDICIAL DISTRICT COURT
TRIAL CAUSE NO. DC-09-559
HON. J. MANUEL BANALES,
PRESIDING JUDGE
____________________________

THE APPELLEES’ UNOPPOSED
MOTION FOR AN EXTENSION OF TIME
TO FILE THEIR REPLY BRIEF
________________________________

TO THE HONORABLE JUSTICES OF SAID COURT:

If this Motion is required under the circumstance of this case’s present status,

the Appellees motion this Court for an Order granting them an extension of time to

file their Reply Brief in response to the Appellants’ Reply Brief and, in support

hereof, show the following:

HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION3.mot Page 1 of 4
 I. APPLICABLE RULES.

The Appellees did not find a Rule expressly-addressing whether there was a

deadline to file their Reply Brief, especially when – as the Court’s web docket shows

on the date this Motion was electronically-filed– no submission date had been set in

this case.

In an abundance of precaution, however, they motion this Court for an Order

granting them an extension of time to file their Reply Brief to on or before 5:00 P.M.,

Friday, 21 August.

III. FACTS IN SUPPORT OF THIS MOTION.

First, although the Appellants’ Reply Brief is not voluminous and principally

relied upon cases the parties cited in their original Briefs, the Appellees ask for a

chance to again look for authorities and Record references that actually or reasonably

support or rebut the Appellants’ cases’ joint and several alleged application to this

appeal’s reasoned disposition.

Second, the undersigned is a sole practitioner who, in addition to working on

other trial and appellate projects, must do everything in this case including, and not

limited to, research, writing, making appropriate copies, sending them, etc.

These duties also apply to his other pending projects.

HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION3.mot Page 2 of 4
 IV. NUMBER OF EXTENSIONS.

This is the Appellees’ first Motion, and barring some really strange unforeseen

event, will be the only one.

V. CONFERENCE WITH THE
APPELLANTS’ APPELLATE COUNSEL

The undersigned conferred with Mr. Miller about his input respecting this

Motion’s allegations, and he graciously stated that the Court could be informed that

he did not oppose it.

Based on the foregoing facts, the Appellees motion this Court for an Order

granting them an extension of time to file their Reply Brief in response to the

Appellants’ Reply Brief to on or before 5:00 P.M., Friday, 21 August.

Respectfully Submitted By:

____ / JOHN A. OLSON/ ________

JOHN A. OLSON
Tex. Bar No. 15274750
20634 Creek River
San Antonio TX 78259-2084
210-307-0336 Office
210-402-3924 Fax
jaolson_ccda@yahoo.com

HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION3.mot Page 3 of 4
 CERTIFICATE OF SERVICE

I hand-delivered a copy of this Unopposed Motion, etc., to the Law Offices of Mr.

Keith P. Miller and Ms. Megan C. Kucera, the Appellants’ Attorneys, on 12 August

2015.

___ /JOHN A. OLSON/ ________

JOHN A. OLSON
jaolson_ccda@yahoo.com

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