in the Interest of C.J.T., a Child ( 2015 )

ACCEPTED
04-14-00621-cv
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
7/14/2015 11:16:30 AM
KEITH HOTTLE
CLERK
CAUSE NO. 04-14-00621-CV
IN THE INTEREST OF § IN THE 49TH JUDICIAL FILED IN
§ 4th COURT OF APPEALS
CARLOS JAVIER TOVAR, § DISTRICT COURT OFSAN ANTONIO, TEXAS
§ 07/14/2015 11:16:30 AM
A CHILD § ZAPATA COUNTY, TEXAS
KEITH E. HOTTLE
Clerk
APPELLEE’S THIRD MOTION FOR
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
Appellee’s FRANCISCO TOVAR GUAJARDO, JR. files this motion for extension of
time and requires an additional thirty days to file his Appellee’s brief, extending the briefing
deadline to August 17, 2015. This is Appellee’s Third and last request for an extension on this
deadline. This extension is not sought for delay.
Appellee’s has been unable to finalize his brief due to his counsel working extensively
Appellee’s brief in another case filed also with this court. In addition Appellee’s counsel has had
numerous court settings on other contested matters in and out of her primary county of practice.
Then moreover, Appellee’s counsel is a sole practitioner with an extensive case load and require
additional time to complete the brief in this case. These obligations have hindered the undersigned
counsel’s ability to complete the brief for this cause by the July 17, 2015 deadline.
Prayer
Appellee’s FRANCISCO TOVAR GUAJARDO, JR. prays that his briefing deadline be
extended to August 17, 2015.
Respectfully Submitted,
/S/FLOR E. FLORES
Flor E. Flores
State Bar No. 24065235
THE LAW FIRM OF FLOR E. FLORES, PLLC
700 N. Flores St., Ste. E
Rio Grande City, Texas 78582
Tel: (956)263-1786
Fax: (956)263-1750
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ffloreslaw@gmail.com
Attorney for Appellees Francisco Tovar
CERTIFICATE OF SERVICE
I hereby certify that on July 14, 2015, a true and correct copy of this document was served
upon counsel for Appellees via electronic service.
Leticia Garcia
Leticia.garcia.atty@gmail.com
Counsel for Irma I. Perez-Chapa
Ricardo Pumarejo Jr.
rpumarejo@ktattorneys.com
Counsel for Maria Del Socorro Gonzalez and Cesario Gonzalez
/S/FLOR E. FLORES
Flor E. Flores
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