Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. De C v. v. Free and Sovereign State of Chihuahua ( 2021 )

ACCEPTED
08-21-00135-CV
EIGHTH COURT OF APPEALS
EL PASO, TEXAS
08-21-00135-CV 10/28/2021 1:03 PM
ELIZABETH G. FLORES
CLERK
IN THE COURT OF APPEALS
FOR THE EIGHTH DISTRICT OF TEXAS
EL PASO, TEXAS FILED IN
8th COURT OF APPEALS
EL PASO, TEXAS
OSVALDO RODRIGUEZ BORUNDA § 10/28/2021 1:03:50 PM
AND EDITORA PASO DEL NORTE, § ELIZABETH G. FLORES
S.A. DE C.V., § Clerk
§
Appellants, §
§
v. § No. 08-21-00135-CV
§
FREE AND SOVEREIGN STATE OF §
CHIHUAHUA, §
§
Appellee. §
APPELLANTS’ FIRST UNOPPOSED MOTION
FOR EXTENSION OF TIME TO FILE REPLY BRIEF
TO THE HONORABLE COURT OF APPEALS:
COMES NOW Osvaldo Rodriguez Borunda and Editora Paso Del Norte,
S.A. de C.V., Appellants, and files this, their First Unopposed Motion for an
Extension of Time to File Appellants’ Reply Brief, and in support thereof, would
respectfully show as follows:
1. Appellants filed their Brief on September 2, 2021.
2. Appellee’s Response Brief was due on September 30, 2021. Appellee
was granted an extension until October 13, 2021 to file his Brief.
3. Appellee filed his Response Brief on October 14, 2021.
{1130.153/HDAV/06856112.1}
4. Appellants’ Reply Brief is due to be filed November 3, 2021.
5. Appellants request an extension of time to November 15, 2021 to file
their Reply Brief.
6. This extension is requested because Appellants’ attorney will be
unable to complete the Reply Brief by the due date because of counsel’s
responsibilities on other urgent client matters.
7. This is Appellants’ first motion for an extension of time to file
Appellants’ Reply Brief. This request is not made for purposes of delay, but so
that justice may be done. Appellee has consented to this request.
8. For these reasons, Appellants, requests an extension of time to
November 15, 2021 to file Appellants’ Reply Brief, and such other and further
relief to which they may be justly entitled.
Respectfully submitted,
GORDON DAVIS JOHNSON & SHANE P.C.
4695 N. Mesa Street
El Paso, Texas 79912
(915) 545-1133
(915) 545-4433 (Fax)
hdavis@eplawyers.com
By: /s/ Harrel L. Davis
Harrel L. Davis III
State Bar No. 05567560
Attorney for Appellants
{1130.153/HDAV/06856112.1}
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was filed with
the Court via the EFile.TXCourts.gov system on October 28, 2021. All attorneys
identified with the Court for electronic service on record in this case were served
by electronic service in accordance with the EFile.TXCourts.gov system.
/s/ Harrel L. Davis
Harrel L. Davis III
CERTIFICATE OF CONFERENCE
The undersigned attorney has conferred with counsel for Appellee who
stated he does not oppose this motion.
/s/ Harrel L. Davis
Harrel L. Davis III
{1130.153/HDAV/06856112.1}
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Virginia Rust on behalf of Harrel Davis III
Bar No. 5567560
vrust@eplawyers.com
Envelope ID: 58633589
Status as of 10/28/2021 2:34 PM MST
Associated Case Party: Editora Paso Del Norte, S.A. de C.V.
Name BarNumber Email TimestampSubmitted Status
Harrel LDavis III hdavis@eplawyers.com 10/28/2021 1:03:50 PM SENT
Virginia Rust vrust@eplawyers.com 10/28/2021 1:03:50 PM SENT
Cynthia Canales ccanales@eplawyers.com 10/28/2021 1:03:50 PM SENT
Victoria Pena vpena@eplawyers.com 10/28/2021 1:03:50 PM SENT
Associated Case Party: Free and Sovereign State of Chihuahua
Name BarNumber Email TimestampSubmitted Status
Jessica Salto jsalto@txattorneys.com 10/28/2021 1:03:50 PM SENT
Caroline Adams cadams@txattorneys.com 10/28/2021 1:03:50 PM SENT
Christopher Leavitt cleavitt@txattorneys.com 10/28/2021 1:03:50 PM SENT
Anthony Buzbee tbuzbee@txattorneys.com 10/28/2021 1:03:50 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
R. Yetter pyetter@yettercoleman.com 10/28/2021 1:03:50 PM SENT
Matthew Zorn mzorn@yettercoleman.com 10/28/2021 1:03:50 PM SENT
Lisa Prince lprince@yettercoleman.com 10/28/2021 1:03:50 PM SENT
Bryce Callahan bcallahan@yettercoleman.com 10/28/2021 1:03:50 PM SENT
Victor Firth vfirth@f-jlaw.com 10/28/2021 1:03:50 PM SENT