ACCEPTED

03-14-00810-CV

5126043

THIRD COURT OF APPEALS

AUSTIN, TEXAS

5/1/2015 4:31:51 PM

JEFFREY D. KYLE

CLERK

No. 03-14-00810-CV 

In the Third Court of Appeals 

For the State of Texas 

Austin, Texas 

STEPHEN D. FOX, 

AS NEXT FRIEND OF 

C.F. and M.F. 

Appellant 

v. 

MIRNA AZUCENA ALBERTO PEREZ 

Appellee 

Appeal from the 207th Judicial District Court of Comal County, Texas 

Cause No. C2014-1631B 

Honorable Dip Waldrip, Presiding 

APPELLANTS' 

SECOND MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANT'S BRIEF 

Motion for Extension of Time/File Brief/ 

New Braunfels, Texas 78131 

(832) 245-2665 

EMailFox.Stephen20 11@ gmail.com 

ATTORNEY FOR APPELLANTS 

1 

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 5/1/2015 4:31:51 PM JEFFREY D. KYLE Clerk
TO THE HONORABLE COURT OF APPEALS: 

COMES NOW, Appellants, STEPHEN D. FOX, as Next Friend of 

C.F. and M.F., and move the Court to grant a Second Motion for Extension 

of Time to File Appellants' Brief herein, and in support thereof would show 

the Court the following: 

1. Appellants' Attorney of Record, STEPHEN D. FOX, has been 

extremely busy in commercial I civil litigation cases Texas as well 

as in Louisiana. The issues that Appellants are researching are 

very technical and require extensive research therein. The court 

hearings and trials, as well as the technical issues concerning the 

this appeal deal with complex issues of law have prevented him 

from completing his research of the law and drafting Appellant's 

Brief herein; although Appellant has been working on that Brief. 

2. STEPHEN D. FOX also has hearing and trial matters pending in 

various District and County Civil courts, for which he must 

exercise due diligence in preparation and presentation at those 

hearings and trial. 

3. STEPHEN D. FOX has also had a matter pending before Louisiana 

District Courts and Courts of Appeals, which matter has taken a 

tremendous amount of Appellant's research and writing time. 

Motion for Extension of Time/File Brief/ 2 
4. For the good cause as shown above, Attorney, STEPHEN D. FOX, 

requires at least an additional three (3) month in which to file 

Appellant's Brief. 

5. Because of the matters, as stated above, STEPHEN D. FOX 

request that the Court grant Appellant a three (3) month extension 

for filing Appellant's Brief. 

6. This Motion of not brought for purposes of delay, but that justice 

might be done. 

WHEREFORE, PREMISES CONSIDERED, Appellants pray that the 

Court grant Appellants' Second Motion for Extension of Time to File 

Appellants' Brief herein, and for such other and further relief, both general 

and special, legal and equitable, to which Attorney, STEPHEN D. FOX, 

may show himself to be justly entitled. 

Motion for Extension of Time/File Brief/ 

Respectfully submitted, 

s£f:~ox~ TBN 07337250 

P.O. Box 312104 

New Braunfels, Texas 78131 

(832) 245-2665 

EMailFox.Stephen20 11@ gmail.com 

ATTORNEY FOR APPELLANTS 

3 
CERTIFICATE OF SERVICE 

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

was served upon all parties entitled to notice per the Texas Rules of Civil 

Procedure on this the J>f day of 

------...~lt"-i4~~~r-+----------' 2015. 

s~~-F~ 

CERTIFICATE OF CONFERENCE 

I do hereby certify that a reasonable effort has been made to resolve 

the dispute without the necessity of intervention and that effort has failed. 

s£~1.15x~ 

Motion for Extension of Time/File Brief/ 4 
AFFIDAVIT 

STATEOFTEXAS § 

§ 

COUNTY OF BEXAR § 

BEFORE ME, the undersigned authority, on this day personally 

appeared STEPHEN D. FOX, who, being by me duly sworn upon his oath 

did depose and say: 

"My name is STEPHEN D. FOX, I am over the age of eighteen (18) 

years, competent to testify, I have personal knowledge of the facts stated 

herein, and all facts stated herein are true and correct. 

I have drafted and read the foregoing Second Motion for Extension of 

Time to File Appellants' Brief and all facts stated therein are true and 

correct. This Motion is not brought for purposes of delay, but that justice 

might be done." 

Further Mfiant Sayeth Naught: ~ 

~~~L~ Sv PHEN D. FOX 

SWORN TO AND SUBSCRIBED BEFORE ME, the undersigned 

/ ){-

authority, on this the __ day of , 2015. 

Notary Public/State of Texas 

My Commission Expires: 

OL/ j,o/zaJfa 

Motion for Extension of Time/File Brief/ 5 
/, the undersigned Notary Public, have verified the identity of the Deponent herein by: 

(A) The deponent is personally known to the notary public; 

(B) The deponent was identified by an identification card 

issued by a governmental agency or a passport issued by the 

United States; or 

(C) The deponent was introduced to the notary public, and, if 

introduced, the name and residence or alleged residence of the 

individual introducing the deponent. Tex. Gov. Code § 

406.014 (1997). 

Motion for Extension of Time/File Brief/ 6