NO. 04-14-00562-CV

IN THE TEXAS COURT OF APPEALS FOR THE FOURTH DISTRICT 

SAN ANTONIO, TEXAS 

* * * * * 

JESUS DE LOS SANTOS, JR., Individually and as Representative of the 

ESTATE OF JESUS FRANCISCO DE LOS SANTOS, and JUAN DE LOS 

SANTOS, Appellants; and MARCO ANTHONY SOLIS, JR., Cross-Appellant, 

v. 

FORD MOTOR COMPANY, 

 Appellee 

* * * * * 

On Appeal from the 79th Judicial District Court 

Jim Wells County, Texas 

Trial Court Cause No. 11-08-50394-CV

* * * * * 

OPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE MOTIONS FOR REHEARING 

* * * * * 

THE HONORABLE JUSTICES OF THE COURT:

Jesus De Los Santos, Jr. Individually and as Representative of the Estate of 

Jesus Francisco De Los Santos and Juan De Los Santos, Appellants, respectfully 

presents this opposed motion requesting that the time for filing Appellant’s motions for 

rehearing be extended twenty (20) days from July 2, 2015 to July 22, 2015. In support of 

this motion, Appellants would show the Court as follows:

1. This motion is being filed prior to the time Appellants’ Motion for 

Rehearing is due. TRAP 49.8. 

2. This appeal involves review of a trial court’s final judgment rendered on

May 15, 2014. 

ACCEPTED

04-14-00562-cv

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

6/24/2015 10:07:03 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 6/24/2015 10:07:03 AM KEITH E. HOTTLE Clerk
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3. Appellants’ motions for rehearing are due on or before July 2, 2015.

4. Appellant request the Court order Appellants’ Reply Brief to be due twenty

(20) days from date the brief is currently due, or on or before July 22, 2015, because of 

significant scheduling conflicts for their appellate counsel as detailed below.

5. Appellate Counsel for Appellant, Brendan K. McBride, has several

scheduling conflicts that coincide with the current filing deadline of July 2, 2015. Mr. 

McBride is preparing for trial of a products liability/wrongful death case in the United 

States District Court for the District of Nevada in a cause styled Lindner v. Evenflo 

Company, Inc., Cause No. 2:20-CV-00051-LDG(VCF). Mr. McBride is responsible for 

preparing trial briefing, motions and jury instructions to be presented at the final pretrial 

conference in the Lindner case, which is set for July 7, 2012 in Las Vegas Nevada. In 

addition, Mr. McBride is the lead appellate counsel for Appellant in case styled Brewer, 

et. al. v. Lowe’s Home Centers, Inc., Cause No. 12-14-00155-CV, pending before the

Twelfth District Court of Appeals in Tyler, Texas. Appellants’ reply brief is due to be 

filed in the Brewer matter on or before July 9, 2015. Finally, Mr. McBride has a 

previously planned personal vacation out of state scheduled for July 2-6, 2015. 

6. In order for their counsel to give the necessary attention to the issues and 

the preparation of the motions for rehearing in this matter, Appellants request a twenty

(20) day extension of time to accommodate these scheduling conflicts.

7. This is the first extension Appellant has requested regarding Appellants’

motions for rehearing.
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8. This extension is not requested for any purpose of delay, but so that justice 

may be done.

9. Certificate of Conference: Counsel for Appellants conferred with Allyson 

Ho, lead appellate counsel for Appellee Ford Motor Company, regarding the relief 

requested in this motion. Ms. Ho represented that Appellees would not agree to the relief 

requested in this motion.

Respectfully submitted,

By: ________________________________

Brendan K. McBride

State Bar No. 24008900

Brendan.mcbride@att.net

THE MCBRIDE LAW FIRM

 Of Counsel to GRAVELY & PEARSON, LLP

425 Soledad, Suite 620

San Antonio, Texas 78205

(210) 227-1200 Telephone

(210) 881-6752 Facsimile

And

Jeffrey G. Wigington

State Bar No. 00785246

jwigington@wigrum.com

R. Reagan Sahadi

State Bar No. 24042369

rsahadi@wigrum.com

WIGINGTON RUMLEY DUNN 

 & BLAIR, LLP

123 N. Carrizo St. 

Corpus Christi, Texas 78401

(361) 881-7500
4

(361) 884-0487 (Facsimile)

COUNSEL FOR APPELLANTS, 

JESUS DE LOS SANTOS, JR. 

INDIVIDUALLY AND AS 

REPRESENTATIVE OF THE 

ESTATE OF JESUS FRANCISCO DE 

LOS SANTOS AND JUAN DE LOS 

SANTOS
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CERTIFICATE OF SERVICE

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

forwarded on this 24

th day of January, 2015 to Appellee’s counsel of record, Allyson Ho

and Cross-Appellant Marco Soliz, Jr.’s lead appellate counsel, Lupita Aguilar, via email

and by electronic service through Texas.gov.

____________________________________

Brendan K. McBride