1 

UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO FILE APPELLEE’S BRIEF 

NO. 04-15-00087-CV

IN THE COURT OF APPEALS FOR THE

FOURTH DISTRICT OF TEXAS AT SAN ANTONIO

ESTATE OF SHIRLEY L. BENSON

THOMAS MILTON BENSON, JR.,

AS TRUSTEE OF THE

SHIRLEY L. BENSON TESTAMENTARY TRUST,

Appellant

v.

RENEE BENSON,

Appellee

On Interlocutory Appeal from Probate Court No. 2, 

Bexar County, Texas

Cause Nos. 155,172 and 155,172-A

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE JUSTICES OF THIS COURT:

Appellee Renee Benson submits this unopposed motion for extension of time to file brief, 

pursuant to TRAP 10.5(b) and states as follows.

1. This is an interlocutory appeal from the trial court’s “Amended Order Granting 

Injunction, Suspending Trustee and Appointing Limited Temporary Co-Receivers 

with Restrictions” signed February 18, 2015. Appellant’s Brief was filed March 

6, 2015. Several days later Appellant Thomas Milton Benson, Jr. as Trustee 

ACCEPTED

04-15-00087-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

6/16/2015 3:48:26 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 06/16/2015 3:48:26 PM KEITH E. HOTTLE Clerk
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UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF

removed this case to federal court, automatically divesting this Court of 

jurisdiction. On March 30, 2015, in light of the removal to federal court, this 

Court decreed this appeal abated and treated for administrative purposes as a 

closed case unless and until reinstated upon issuance of a remand order from the 

federal court. 

2. The federal court on June 9, 2015 issued an order granting Renee Benson’s 

motion to remand this case to state court. On June 12 Appellant submitted a letter 

informing this Court of such remand. Pursuant to Appellant’s letter, Appellee’s 

brief would be due 14 days later, on June 26, 2015. 

3. Appellee requests an extension to July 10, 2015 of her due date for the filing of 

Appellee’s Brief. This request is due to several factors, including the complexity 

of the issues, and the workload and schedules of Appellees’ counsel. 

4. There have been no extensions previously granted Appellee. 

5. The undersigned counsel conferred with opposing counsel, David Beck, Esq., 

concerning this request. Appellant’s counsel stated in an email that this request 

for extension will not be opposed. 

WHEREFORE, Appellee Renee Benson respectfully requests that the due date for her

Appellee’s Brief be extended to July 10, 2015.
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UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF

Respectfully submitted,

 /s/ Bennett L. Stahl

Bennett L. Stahl

State Bar No. 19006500

blstahl@csg-law.com

CURL STAHL GEIS

A PROFESSIONAL CORPORATION

One Riverwalk Place

700 North St. Mary’s Street, Ste. 

1800

San Antonio, Texas 78205

Telephone: (210) 226-2182

Telecopier: (210) 226-1691

Emily Harrison Liljenwall

State Bar No. 12352250

eliljenwall@scs-law.com

SCHOENBAUM, CURPHY 

& SCANLAN, P.C.

112 E. Pecan, Suite 3000

San Antonio, Texas 78205

Telephone: (210) 224-4491

Telecopier: (210) 224-7983

Harriet O’Neill

State Bar No. 00000027

honeill@harrietoneilllaw.com

LAW OFFICE OF

HARRIET O’NEILL, P.C.

919 Congress Avenue, Suite 1400

Austin, Texas 78701

Telephone: (512) 944-2222

Telecopier: (512) 476-6441

Douglas W. Alexander

State Bar No. 00992350

dalexander@adjtlaw.com

Amy Warr

State Bar No. 00795708

awarr@adjtlaw.com

ALEXANDER DUBOSE 

JEFFERSON & TOWNSEND LLP

515 Congress Avenue, Suite 2350

Austin, Texas 78701-3562

Telephone: (512) 482-9300

Facsimile: (512) 482-9303

Attorneys for Appellee Renee Benson
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UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE APPELLEE’S BRIEF

CERTIFICATE OF CONFERENCE

The undersigned counsel certifies that on June 15, 2015, I conferred with 

David Beck, counsel for Appellant Thomas Milton Benson, Sr., as Trustee of the 

Shirley L. Benson Testamentary Trust, regarding this motion for extension of time, 

and he indicated that he does not oppose the relief sought in this motion. 

/s/ Bennett L. Stahl

Bennett L. Stahl

CERTIFICATE OF SERVICE

On June 16, 2015, I electronically filed this Brief of Appellee with the Clerk 

of the Court using the eFile.TXCourts.gov electronic filing system which will send 

notification of such filing to the following: 

David J. Beck, Esq.

Russell Post, Esq.

Troy R. Ford, Esq.

BECK REDDEN LLP

1221 McKinney Street, Suite 4500

Houston, Texas 77010-2010

Telecopier: (713) 951-3720

dbeck@beckredden.com

rpost@beckredden.com

tford@beckredden.com

/s/ Bennett L. Stahl

Bennett L. Stahl