01-14-00552-CV

In the First Court of Appeals

Houston, Texas

MARIBEL AMBRIZ MARTINEZ, GUADALUPE MOTA, AND ROSA NELLY TREVINO,

Appellants,

V.

ALFREDO GONZALEZ,

Appellee.

SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLEE ’ S BRIEF

CARL J. KOLB

State Bar No. 11660480

carl@carlkolblaw.com

CARL J. KOLB , P.C.

925 Chulie Drive

San Antonio, Texas 78216

Telephone: (210) 225-6666

Facsimile: (210) 225-2300

ELIZABETH CONRY DAVIDSON

Of Counsel

State Bar No. 00793586

conrydavidson@gmail.com

925 Chulie Drive

San Antonio, Texas 78216

Telephone: (210) 380-4899

Facsimile: (210) 225-2300

Counsel for Appellee

ACCEPTED

01-14-00552-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

2/4/2015 10:52:45 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 2/4/2015 10:52:45 AM CHRISTOPHER A. PRINE Clerk
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TO THE HONORABLE JUDGES OF THIS COURT:

Appellee, Alfredo Gonzalez respectfully presents this Second

Unopposed Motion for Extension of Time to file his Appellee’s Brief in this 

matter, requesting that the time to file the Brief be extended by thirty days

from February 4, 2015 until March 6, 2015 as allowed by TEX. R. APP. P.

10.5(b) and 38.6. In support of this Motion, Appellee would show the Court 

as follows:

The Appellants filed their Brief in this case on December 5, 2014,

making the Appellee’s Brief due on January 5, 2015, which was extended to 

February 4, 2015. Due to the litigation, work and vacation schedule of 

counsel for Appellee, a second thirty-day extension of time is sought to file 

the Brief, up until March 6, 2015. This extension of time is not sought for 

delay, but only so that justice may be done.

The numerous matters that the undersigned must attend to in their

law practices on a daily basis make it so that they will be unable to 

complete the response requested in this case by the current due date. 

Consequently, the Appellee respectfully requests an extension of time for 

thirty (30) days, up through and including March 6, 2015. 
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This is the Appellee’s second request for an extension of time to file 

the motion.

The undersigned counsel for Appellee has conferred with counsel for 

the Appellant, Michael J. Murray, and he has indicated he is unopposed to 

the extension.

Consequently, based on the foregoing, Appellee respectfully requests

an extension of time to file the Appellee’s Brief in this case for thirty days, 

so that filing March 6, 2015 will be considered timely. This extension of 

time is not sought for delay, but only so that justice may be done.

WHEREFORE, PREMISES CONSIDERED, Appellee prays that this 

Court will grant the extension requested above.

Respectfully submitted,

CARL J. KOLB, P.C.

Carl J. Kolb

Conry Davidson, Of Counsel

926 Chulie Drive

San Antonio, Texas 78216

Telephone No. (210) 225-6666

Facsimile No. (210) 225-2300

carl@carlkolblaw.com

conrydavidson@gmail.com

/s/ Elizabeth Conry Davidson

Carl J. Kolb

State Bar No. 11660480

Elizabeth Conry Davidson
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State Bar No. 00793586

ATTORNEYS FOR APPELLEE

CERTIFICATE OF CONFERENCE

I hereby certify that I have conferred with opposing counsel, Michael 

J. Murray regarding the subject matter and substance of the foregoing 

Motion and he has indicated that he does not oppose this Motion. 

/s/Elizabeth Conry Davidson

ELIZABETH CONRY DAVIDSON

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing 

instrument was delivered to the following in accordance with the Texas 

Rules of Civil and Appellate Procedure on this the 4th day of February, 

2015:

Michael J. Murray

Watts Guerra, LLP

4 Dominion Drive

Building 3, Suite 100

San Antonio, Texas 78257

Michael Miller

Law Office of Michael Miller

926 Chulie Drive

San Antonio, Texas 78216

/s/ Elizabeth Conry Davidson

CARL J. KOLB

ELIZABETH CONRY DAVIDSON