# 0 1

- 1 4

- 00 552

- CV

In the F irst Court of Appeals

Houston , Texas

M ARIBEL A MBRIZ M ARTINEZ

, G UADALUPE M OTA

, AND R OSA N ELLY T REVINO

, Appellants

,

V

.

A LFREDO G ONZALEZ

, Appellee

.

S ECOND U NOPPOSED M OTION FOR E XTENSION OF T IME TO F ILE

A PPELLEE ’ S B RIEF

CARL J. KOLB

State Bar No. 11660480

carl@carlkolblaw.com

C ARL J. K OLB

, 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

CLERK2 TO THE HONORABLE JUD GES OF THIS COURT:

Appellee, Alfredo Gonzalez respectfully present s this Second

Uno pposed Motion for Extension of Time to file h is 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 T EX

. R. A PP

. 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 thi s case on December 5 , 2014

,

making the Appellee’s Brief due on January 5 , 201 5 , 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 t h e i r

law practice s on a dail y basis make it so that t he y will be unable to

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

Consequently, the Appellee respectfully request s an extension of time for

thirty ( 30 ) days, up through and including March 6 , 2015

.3 This is the Appellee’s second request for an extension of time to file

the motion

.

The undersigned counsel for Appellee has confer red with counsel for

the Appellant

, Michael J. Murray

, and he has indicated he is uno pposed to

the extension.

Consequently, based on the foregoing, Appellee respectfully request s

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 pray s 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 Davidson4 State Bar No. 00793586

ATTORNEYS FOR APPELLEE

CERTIFICATE OF CONFERENCE

I hereby certify that I have confer red 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 4 th day of Febr uary,

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