NO. 04-014-00494-CV

IN THE FOURTH COURT OF APPEALS 

SAN ANTONIO, TEXAS

UNITED PARCEL SERVICE, INC. and ROLAND LEAL

Appellants/Cross-Appellees

v.

ROBERT SCOTT RANKIN, Individually; RACHELLE RANKIN,

Individually and as Next Friend for AVERY RANKIN, a Minor; as Next

Friend for KARA RANKIN, a Minor; and as Next Friend for SAMUEL

RANKIN, a Minor

Appellees/Cross-Appellants

On Appeal from the 224 Judicial District Court, Bexar County, Texas th

Honorable Cathy Stryker, Presiding Judge

Trial Court Cause No. 2011-CI-07922

APPELLEES’ UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO FILE RESPONSE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Appellees, Robert Scott Rankin, Rachelle Rankin, Avery Rankin, Kara Rankin,

and Samuel Rankin, by and through their undersigned attorneys, hereby move the

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 1 of 4

ACCEPTED

04-014-00494-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

1/15/2015 9:45:06 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 01/15/2015 9:45:06 AM KEITH E. HOTTLE Clerk
Court for an Order extending the time to file Appellees’ Response Brief, and as

grounds therefor would show the Court the following:

1. Appellees’ Response Brief is due on or before January 20, 2015.

2. Appellees respectfully request that the Court extend their current briefing

deadline of January 20, 2015, to and including January 30, 2015. No previous

extension of time has been granted for the filing of Appellees’ Response Brief.

3. Undersigned counsel has had an unusually busy schedule in December and

January, primarily due to the holiday season and the work required to prepare for

vacation time around the holiday season. Given that, undersigned counsel has not

had, and will not have, an opportunity to properly prepare the brief on the issues in

this matter by the current deadline.

WHEREFORE, Appellees pray that the time for filing their response brief be

extended to and including January 30, 2015; and for such other and further relief as

the Court may deem to be just and proper.

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 2 of 4
Respectfully submitted,

THE PERRIN LAW FIRM

1910 Pacific Avenue, Suite 6050

Dallas, Texas 75201

Telephone: (214) 646-2004

Facsimile: (214) 646-6117

Email: dougperrin@perrinlaw.org

 markperrin@perrinlaw.org

/s/J. Mark Perrin 

Doug Perrin

State Bar No. 15796520

J. Mark Perrin

State Bar No. 24013313

REESE GORDON MARKETOS LLP 

750 N. St. Paul Street, Suite 610 

Dallas, Texas 75201

Telephone: (214) 382-9810

Facsimile: (214) 501-0731

Email: pete.marketos@rgmfirm.com

Pete Marketos

State Bar No. 24013101 

KEELING & DOWNES, P.C.

1500 McGowen Street

Houston, Texas 77004

Telephone: (832) 214-9900

Fax: (832) 214-9908

Email: bck@keelingdownes.com

Byron Keeling

State Bar No. 11157980

ATTORNEYS FOR 

CROSS-APPELLANTS

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 3 of 4
CERTIFICATE OF CONFERENCE

I have conferred with counsel for Appellants/Cross-Appellees about the merits

of this Motion and was advised that Appellants/Cross-Appellees do not oppose the

relief requested in this Motion. 

Certified this 15 day of January, 2015.

th

/s/J. Mark Perrin 

J. Mark Perrin

CERTIFICATE OF SERVICE

This will certify that a true and correct copy of the above and foregoing

document was forwarded to all counsel of record in the above cause through the

Court’s electronic case filing system, on this the 15 day of January, 2015.

th

Ricardo Reyna

Audrey Haake

Brock, Person, Guerra, Reyna P.C.

17339 Redland Road

San Antonio, Texas 78247

W. Randall Bassett

Bradley Pratt

King & Spalding, LLP

1180 Peachtree Street, NE

Atlanta, Georgia 30309

H. Victor Thomas

King & Spalding, LLP

1100 Louisiana, Suite 4000

Houston, Texas 77002

/s/J. Mark Perrin 

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE BRIEF - Page 4 of 4