Herbert Rolnick v. Sight's My Line, Inc., a Florida Corporation Stewart Lantz Riggs, Aleshire & Ray Blazier, Christensen, Bigelow & Vir, P.C. And Adams & Graham ( 2015 )

ACCEPTED
03-15-00335-CV
6256176
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/28/2015 2:36:11 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00335-CV
FILED IN
IN THE COURT OF APPEALS FOR THE THIRD JUDICIAL3rd COURT OF APPEALS
DISTRICT
AUSTIN, TEXAS
AUSTIN, TEXAS 7/28/2015 2:36:11 PM
JEFFREY D. KYLE
Clerk
HERBERT ROLNICK
Appellant,
v.
SIGHT’S MY LINE, INC.; STEWART LANTZ; RIGGS, ALESHIRE & RAY, P.C.;
BLAZIER, CHRISTENSEN, BIGELOW & VIRR, P.C.; ADAMS & GRAHAM, L.L.P.
Appellees.
On Interlocutory Appeal from the
200th Judicial District Court Travis County, Texas
APPELLEE ADAMS & GRAHAM, L.L.P.’S
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE COURT:
Appellee Adams and Graham, L.L.P. respectfully files this unopposed
motion asking the Court to extend the deadline to file its Appellee’s Brief by seven
days, from July 29, 2015 to August 5, 2015.
In support of its motion, Appellee shows as follows:
1. Appellee’s brief is due on or before July 29, 2015.
{00156739}
2. Appellee requests an additional seven days in which to file its brief due to its
lead counsel’s previous commitments before Appellant’s brief was filed.
Appellee’s lead counsel has participated in two full day mediations, one of
them requiring travel to Midland. Lead counsel has also conducted full day
mediation. All mediations have required extensive preparation. Lead counsel
has also traveled out of town to present at the 2015 Texas Bar CLE for
Advanced Insurance Law. The foregoing, in addition to work in other cases,
will prevent the undersigned from completing Movant’s brief by the current
deadline.
3. This is Appellee’s first motion for an extension of time to file its brief.
4. The relief sought by this motion is so that justice may be done, and is not
sought solely for delay, or any other improper purpose.
5. The Court has already granted an extension of time for Co-Appellees
Stewart Lantz and Sight’s My Line, Inc. to file their brief until August 5,
2015. Thus, the Court’s consideration of this case will not be impaired by
granting the relief sought by Appellee Adams and Graham, L.L.P.
6. Appellee therefore prays that the Court extend the current deadline for its
brief from July 29, 2015 until August 5, 2015.
{00156739}
Respectfully submitted,
VALDEZ, JACKSON & TREVIÑO, P.C.
Plaza Las Campanas
1826 N. Loop 1604 W. Suite 245
San Antonio, Texas 78248
210-598-8686 – Telephone
210-598-8797 – Fax
/S/ Robert E. Valdez
Robert E. Valdez
State Bar No. 20428100
revaldez@vjtlawfirm.com
Joseph E. Cuellar
State Bar No. 24082879
jcuellar@vjtlawfirm.com
ATTORNEYS FOR APPELLEE ADAMS &
GRAHAM, L.L.P.
{00156739}
CERTIFICATE OF CONFERENCE
The undersigned has communicated with counsel for all parties, all of whom
stated they do not oppose Appellee Adams & Graham’s Unopposed Motion
Extension of Time to File Brief.
/s/ Joseph E. Cuellar
Joseph E. Cuellar
{00156739}
CERTIFICATE OF SERVICE
I certify that the forgoing document has been served upon the following
counsel of record via electronic service on July 28, 2015:
J. Hampton Skelton Craig S. Hilliard
Brandon Gleason STARK & STARK
SKELTON & WOOD A Professional Corporation
248 Addie Roy Road, Suite B-302 P.O. Box 5315
Austin, Texas 78746 Princeton, New Jersey 08543-2315
Attorneys for Plaintiffs Attorneys for Plaintiffs
Michael B. Johnson Scott R. Kidd
THOMPSON COE, COUSINS & IRONS, Scott V. Kidd
L.L.P. KIDD LAW FIRM
701 Brazos, Suite 1500 819 W. 11th Street
Austin, Texas 78701 Austin, Texas 78701
Attorneys for Defendant Blazier, Attorneys for Defendant Riggs Aleshire
Christensen, Bigelow & Virr, P.C. & Ray, P.C.
Ruth Malinas
Tim T. Griesenbeck
Scott M. Noel
PLUNKETT & GRIESENBECK, INC.
1635 N. E. Loop 410 Suite 900
San Antonio, Texas 78209
Attorneys for Defendant Herbert
Rolnick
/s/ Joseph E. Cuellar
Joseph E. Cuellar
{00156739}