Ramiro and Edna Ramos, and Federico Salazar, Jr. v. the Unknown Heirs of Tomasa Gonzalez and Narciso Gonzalez ( 2015 )

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 HPLAPTOPAMD\DOCUMENTS\RRAMOS\EXTENSION3.mot Page 4 of 4