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No. 05-16-00332-CV INTHE FIFTHDISTRICT COURT OFAPPEALS AT DALLAS, TEXAS

INRE ANTHONYR. SANDERS, RELATOR OriginalProceedingArising out ofthe 296TH Judicial District Court ofCollin County, Texas Cause No. 296-56252-2012 Honorable JohnRoach, Jr. Presiding

REAL PARTYIN INTEREST'S SECOND MOTIONFOREXTENSION OF TIME TO FILE PAST DUE RESPONSE TO PETITIONFORWRIT OF MANDAMUS
Respectfully submitted,

# By:~ CASEY T. BOYD State BarNo. 24059477 THE SHAPIRO LAW FIRM 701 E. 15th Street, Suite 204 Plano, Texas 75074 Tel: (972) 423-0033 Fax: (972) 423-0077 Email: cboyd@shapiro-law.net

COUNSELFORREALPARTYININTEREST EDV ANIA SANDERS ACCEPTED 05-16-00332-CV FIFTH COURT OF APPEALS

DALLAS, TEXAS 4/21/2016 4:39:35 AM

LISA MATZ CLERKi I

REAL PARTY IN INTEREST'S SECOND MOTIONFOR EXTENSION OF TIME TO FILE PAST DUE RESPONSE TO PETITION FORWRIT OF MANDAMUS TO THE HONORABLE FIFTH COURT OF APPEALS: Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Real Party in Interest, Edvania Sanders, files this Second Motion to Extend Time to File her Past Due Response to the Petition for Writ ofMandamus. On March 30, 2016, this Court issued an Order requesting that Real Party in Interest and Respondent file their responses to the Petition for Writ ofMandamus, ifany, on or before April 14, 2016. On April 13, 2016, Counsel for Real Party in Interest requested a 7-day extension of time to file her response, making the response due on Wednesday, April 20, 2016. Thatwas her first request for extension oftime to file the response. On April 14, 2016, this Court granted Real Party in Interest's Motion to Extend Time, and directed Real Party in Interest to file her response, ifany, on or before April 20, 2016. Prior to filing this Second Motion for Extension of Time to File Past Due Response to Petition for Writ ofMandamus, Real Party in Interest did in fact file her Response with the Court. Her Response was filed with the Court four (4) hours late.



### 2Counsel for Real Party in Interestrelies on the following reasons, in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the second requested extension oftime: Counsel for Real Party in Interest was unable to properly convert the Response to text searchable portable document format per the applicable Rules ofCourtprior to the deadline to file. Counsel for Real Party in Interest needed additional time ( 4 hours) to file the response so that he could get to his office in order to properly convertthe Response to text searchable portable document format. Counsel for Real Party in Interest seeks this extension oftime to file the past due Response so that this Court can be aided in its analysis ofthe issues presented. This request is not sought for delay but so thatjustice maybe done. The undersigned has not conferred with Relator's counsel of record, Georganna Simpson, prior to the filing ofthis motion because this motion is being filed contemporaneously with the past due Response. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2. PRAYER FORRELIEF Forthe reasons set forth above, Real Party in Interestrequests that this Court grant this Second Motion to Extend Time to File Past Due Response to Petition for

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Writ ofMandamus and extend the Deadline for Filing the Real Party in Interest's Response up to and including April 21, 2016. Real Party inInterestrequests all otherreliefto which she may be entitled. Respectfully submitted, THE SHAPIRO LAWFIRM 701 E. 15th Street, Suite 204 Plano, Texas 75074 Tel: (972) 423-0033 Fax: (972) 423-0077 Email: familylaw@shapiro-law.net

# By:~ CASEY T. BOYD State BarNo. 24059477 COUNSELFORREAL PARTYIN INTEREST

CERTIFICATE OF CONFERENCE I have not conferred with counsel for Relator regarding this motion because this motion was filed contemporaneously with Real Party in Interest's Response to Petition for Writ ofMandamus.
CASEY T. BOYD Counsel for Real Party in Interest

4CERTIFICATE OF SERVICE I certify that on April 21, 2016, I served a copy of this motion to the following counsel andparties by electronic mail or via facsimile. Georganna L. Simpson Counsel forRelator Beth M. Hearn Counsel for Relator TheHonorable John Roach, Jr. 296th Judicial District Court Collin County, Texas Respondent

COUNSELFORREALPARTYININTEREST

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