Kyu Im Robinson v. William P. RIDDICK, Individually and as Trustee of the Cynthia Riddick Marmolejo 76 Trust, the William McDonald Riddick 76 Trust, the Warren Pretlow 76 Trust, and the Patricia Swann Riddick 76 Trus

ACCEPTED 04-15-00272-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 9/4/2015 3:24:56 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 9/4/2015 3:24:56 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 APPELLEES’ SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF TO THE HONORABLE FOURTH COURT OF APPEALS: 1. Appellees, William P. Riddick, Individually, and sued as Trustee of the Wm. P. Riddick – 76 Trust, file this Second Motion for Extension of Time to File Appellees’ Brief and respectfully request an additional 30-day extension of its filing deadline. Appellees’ Second Motion for Extension of Time 2. The Court has granted one previous request by Appellees’ for an extension of time. The current deadline to file Appellees’ Brief is September 21, 2015. 3. Appellees’ current counsel seeks an additional 30-day extension of the deadline to file Appellees’ Brief based on its First Amended Motion to Withdraw from representation currently pending before this Court. 4. Counsel’s First Amended Motion to Withdraw is based on the fact that counsel is not able to effectively communicate with Appellees in a manner consistent with good attorney-client relations. As more fully set forth in its First Amended Motion to Withdraw, filed this same day, until just recently counsel communicated only with Mr. William P. Riddick, acting individually as well as in his capacity as Trustee for the four trusts collectively referred to as the Wm. P. Riddick—76 Trusts. On June 15, 2015, Mr. Riddick’s appointment as Trustee expired. To counsel’s knowledge, no successor trustee has been appointed. The beneficiaries, whether among themselves or with Mr. Riddick, individually, do not speak with one voice, and counsel is not otherwise able to effectively communicate with them. Additionally, and despite requests otherwise, counsel remains unpaid for fees incurred from December 2014 through June 20, 2015. 5. Counsel for Appellee’s has, since August 27, 2015, been in the process of attempting to secure permission of this Court to withdraw. Even before Appellees’ Second Motion for Extension of Time Page 2 Sak:\7606\001\Appeal\Mtn-Extension[2nd] filing the Motion to Withdraw, Appellees were informed of counsel’s intention to do so if certain action was not collectively and uniformly undertaken. Additionally, on information and belief, since before August 2015, at least certain of the Appellees were engaged in action regarding the possibility of retaining different counsel for appeal. 6. Counsel requests this extension so that ample time may be afforded, to either Appellees’ current counsel or their substitute counsel, the time necessary to adequately prepare a responsive brief following the Court’s ruling on the First Amended Motion to Withdraw. 7. CERTIFICATE OF CONFERENCE: Counsel for Appellees has attempted to confer with counsel for Appellant via telephone and email. At the filing of this Motion, Counsel for Appellees had not yet received a response from counsel for Appellants on whether there was opposition to this motion. WHEREFORE PREMISES CONSIDERED, counsel for Appellees requests the Court grant this second motion and extend the time for filing Appellees’ Brief to October 21, 2015. Appellees’ Second Motion for Extension of Time Page 3 Sak:\7606\001\Appeal\Mtn-Extension[2nd] Respectfully submitted, RICHIE & GUERINGER, P.C. BY: /s/ Gay Gueringer GAY GUERINGER State Bar No. 08571400 KATHERINE J. WALTERS State Bar No. 00785174 112 East Pecan Street, Suite 1420 San Antonio, Texas 78205 Telephone: 210-220-1080 Facsimile: 210-220-1088 Email: ggueringer@rg-sanantonio.com Email: kwalters@rg-austin.com ATTORNEYS FOR APPELLEES CERTIFICATE OF SERVICE By my signature below, I hereby certify that a true and correct copy of the above and foregoing has been served via electronic service to all counsel of record listed below on this 4th day of September 2015. Ms. JoAnn Storey JoAnn Storey, P.C. 1005 Heights Boulevard Houston, Texas 77008 /s/ Gay Gueringer Gay Gueringer / Katherine J. Walters Appellees’ Second Motion for Extension of Time Page 4 Sak:\7606\001\Appeal\Mtn-Extension[2nd]