NO. 03 -14-00819- CV

IN THE COURT OF APPEALS FOR THE

THIRD COURT OF APPEALS DISTRICT

AUSTIN, TEXAS

Judy Weirich

v.

IESI Corp. and Southside Wrecker, Inc.

APPELLANT ’ S MOTION FOR EXTENSION OF TIME TO

FILE BRIEF OF APPELLANT

TO THE HONORABLE COURT OF APPEALS:

Appellant Judy Weirich , respectfully present this motion to extend time to file her brief

pursuant to T EX

. R. A PP

. P. 10.5(b) and 38.6(d). In support of her motion, Appellant would show

the Court as follows:

I.

This Court received the clerk’s record on February 4, 2015

. This Court received the

court reporter’s record on February 5, 2015.

II.

Appellant request s an additional 30 days from March 9 , 2015

, or up to and including

April 8 , 201 5 within which to file the brief. This extension is necessary because the following

matters have prevented the completion of the brief and/or will preclude the undersigned from

doing so sooner than March 9 , 2015:

Personal and business commitments of Appellant’s counsel which prohibited counsel

from preparing the brief within the deadline.

Page 1 of 3 ACCEPTED

03-14-00819-cv

4426796

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/9/2015 4:11:16 PM

JEFFREY D. KYLE

CLERKFor th is reason, the undersigned did not complete the Appellant ’ s brief by its current due

date and respe ctfully requests an ad ditional 3 0 days from March 9, 2015 within which to do so.

The extension is not sought only for delay, but so that justice can be done.

WHEREFORE, PREMISES CONSIDERED, Appell ant respectfully request s that the

Cour t grant her motion for extens ion of time i n which to file her b rief, extend the current March

9

, 2015 deadline 30 days from the date of filing this app eal , up to and including April 8 , 201 5

and that the Court grant such other and further relief to which Appellant may show herself to be

justly and equitably entitled.

Respectfully submitted,

ZACHARY P. HUDLER, P.C.

By: /S/ Zachary P. Hudler

Zachary P. Hudler

Zachary P. Hudler

State Bar No. 24032318

P.O. Box 1728

100 E. Pecan Street, Suite One

Johnson City, Texas 78636

830.868.7651 (Telephone)

830.868.7636 (Facsimile)

ATTORNEY FOR APPELLANT

Page 2 of 3CERTIFICATE OF CONFERENCE

I hereby certify that Counsel for Appellant attempted to confer with IESI Corp. ’s attorney

Vaughan Waters by telephone

, on March 9, 2015 regarding the merits of this Motion but was

unable to reach him. Counsel for Appellant conferred with George Petras, counsel for Southside

Wrecker , Inc. and he stated that he was not opposed to this request

. T his motion is being

presented for the court’s consideration.

/S/ Zachary P. Hudler

Zachary P. Hudler

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing has been sent to counsel listed below in the

following manner on this the 9th day of March, 2015

.

VIA E

- SERVICE

Mr. George J. Petras IV

The Petras Law Firm

1504 San Antonio Street

Austin, Texas 78701

Attorney for Southside Wrecker, Inc.

gpetras@petraslawfirm.com

VIA E

- SERVICE

Mr. Vaughan Waters

Thorton, Biechlin, Segrato, Reynolds & Guerra, L.C.

100 N.E. Loop 410

San Antonio, Texas 78216

Attorneys for IESI Corporation

vwaters@thortonfirm.com

_ /S/ Zachary P. Hudler

Zachary P. Hudler

Page 3 of 3