{1130.153/HDAV/06856112.1}

IN THE COURT OF APPEALS 

FOR THE EIGHTH DISTRICT OF TEXAS 

EL PASO, TEXAS 

OSVALDO RODRIGUEZ BORUNDA 

AND EDITORA PASO DEL NORTE, 

S.A. DE C.V., 

 Appellants, 

v. 

FREE AND SOVEREIGN STATE OF 

CHIHUAHUA, 

 Appellee. 

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No. 08-21-00135-CV 

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. 

ACCEPTED

08-21-00135-CV

EIGHTH COURT OF APPEALS

EL PASO, TEXAS

10/28/2021 1:03 PM

ELIZABETH G. FLORES

CLERK

08-21-00135-CV

 FILED IN 8th COURT OF APPEALS EL PASO, TEXAS 10/28/2021 1:03:50 PM ELIZABETH G. FLORES Clerk
{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 
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

Harrel LDavis III

Virginia Rust

Cynthia Canales

Victoria Pena

BarNumber Email

hdavis@eplawyers.com

vrust@eplawyers.com

ccanales@eplawyers.com

vpena@eplawyers.com

TimestampSubmitted

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

Status

SENT

SENT

SENT

SENT

Associated Case Party: Free and Sovereign State of Chihuahua

Name

Jessica Salto

Caroline Adams

Christopher Leavitt

Anthony Buzbee

BarNumber Email

jsalto@txattorneys.com

cadams@txattorneys.com

cleavitt@txattorneys.com

tbuzbee@txattorneys.com

TimestampSubmitted

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

Status

SENT

SENT

SENT

SENT

Case Contacts

Name

R. Yetter

Matthew Zorn

Lisa Prince

Bryce Callahan

Victor Firth

BarNumber Email

pyetter@yettercoleman.com

mzorn@yettercoleman.com

lprince@yettercoleman.com

bcallahan@yettercoleman.com

vfirth@f-jlaw.com

TimestampSubmitted

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

10/28/2021 1:03:50 PM

Status

SENT

SENT

SENT

SENT

SENT