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 TEX. R. APP. 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 requests an additional 30 days from March 9, 2015, or up to and including 

April 8, 2015 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

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/9/2015 4:11:16 PM JEFFREY D. KYLE Clerk
For this reason, the undersigned did not complete the Appellant’s brief by its current due 

date and respectfully requests an additional 30 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, Appellant respectfully requests that the 

Court grant her motion for extension of time in which to file her brief, extend the current March 

9, 2015 deadline 30 days from the date of filing this appeal, up to and including April 8, 2015

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 3
CERTIFICATE 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. This 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