City of San Antonio v. Roxana Tenorio, Individually and on Behalf of Pedro Tenorio ( 2015 )

ACCEPTED 04-15-00259-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 5/19/2015 9:52:55 PM KEITH HOTTLE CLERK NO. 04-15-00259-CV FILED IN 4th COURT OF APPEALS IN THE COURT OF APPEALS SAN ANTONIO, TEXAS FOURTH COURT OF APPEALS DISTRICT OF TEXAS 05/19/2015 9:52:55 PM SAN ANTONIO, TEXAS KEITH E. HOTTLE Clerk CITY OF SAN ANTONIO APPELLANT V. ROXANA TENORIO, INDIVIDUALLY AND ON BEHALF OF PEDRO TENORIO, DECEASED APPELLEE APPELLANT’S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF THE COURT: CITY OF SAN ANTONIO, Appellant, submits its First Unopposed Motion for Extension of Time to File Appellant’s Brief and in support of this motion states as follows: 1. Appellant’s Brief is due May 27, 2015. 2. This motion is filed prior to the expiration of this due date. 3. The undersigned has conferred with the attorney for Appellee and this motion is unopposed. 4. Appellant requests an additional thirty (30) days to file its Appellant’s Brief, extending the time to June 26, 2015. 5. No extension has previously been granted. 6. The undersigned is responsible for the preparation of this Appellant’s Brief. The undersigned requested the Clerk’s Record on April 28, 2015. CR 78. The record, when filed, did not contain all of the requested items. Those additional items were filed yesterday. The undersigned intends to pick up a copy of that record from the Fourth Court clerk’s office within the next few days. 7. The undersigned has numerous previously scheduled mediations he is required to conduct. This extension request is not filed for purposes of delay. PRAYER Appellant asks this Court to grant its motion extending the deadline to file its Appellant’s Brief to June 26, 2015. Respectfully submitted, CITY OF SAN ANTONIO Martha G. Sepeda, Acting City Attorney State Bar No. 13143100 Michael D. Siemer, Assistant City Attorney State Bar No. 18343670 Office of the City Attorney Litigation Division 111 Soledad Street, 10th Floor San Antonio, TX 78205 (210) 207-8784 – Phone (210) 207-4357 – Fax 2 LAW OFFICE OF DAN POZZA 239 E. Commerce Street San Antonio, TX 78205 (210) 226-8888 – Phone (210) 224-6373 – Fax danpozza@yahoo.com /s/Dan Pozza State Bar No. 16224800 ATTORNEYS FOR APPELLANT CERTIFICATE OF SERVICE I hereby that a true and correct copy of the above and foregoing document has been delivered via e-mail transmission on this 20th day of May, 2015, to: Joe Brad Brock Law Office of Joe Brad Brock 5866 S. Staples, Suite 103 Corpus Christi, TX 78413 joebrad@thebrocklawfirm.com /s/Dan Pozza 3