No. 01-14-00552-CV

* * * 

IN THE COURT OF APPEALS

FIRST COURT OF APPEALS DISTRICT

HOUSTON, TEXAS

* * * 

MARIBEL AMBRIZ MARTINEZ, GUADALUPE MOTA, 

AND ROSA NELLY TREVINO,

Appellants,

v.

ALFREDO GONZALEZ,

Appellee.

* * * 

On Appeal from the 365th Judicial District Court 

of Maverick County, Texas

* * * 

APPELLANTS’ SECOND UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO FILE REPLY BRIEF

TO THE HONORABLE FIRST COURT OF APPEALS:

MARIBEL AMBRIZ MARTINEZ, GUADALUPE MOTA, and 

ROSA NELLY TREVINO, Appellants in this matter, respectfully file 

this motion requesting an extension of time to file their reply brief in 

this cause. By this motion, Appellants seek an extension of 21 days 

from the current due date of April 15, 2015 to May 6, 2015. Counsel for 

Appellee does not oppose the relief sought by this motion. 

ACCEPTED

01-14-00552-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/10/2015 2:32:31 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/10/2015 2:32:31 PM CHRISTOPHER A. PRINE Clerk
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 2

I.

Following two extensions of time, Appellants filed their brief on 

December 5, 2014. Appellee likewise received two extensions of time to 

file his brief and filed that brief on March 6, 2015. Appellants have 

previously filed one motion for extension of time -- and were granted an 

additional 20 days -- to file their reply brief, which is presently due to be 

filed on or before April 15, 2015.

II.

In the time preceding the due date for Appellants’ reply brief, the 

undersigned has had the following commitments that have prevented 

immediate work on the brief and its completion by the current deadline. 

Those commitments include, but are not limited to, the following:

(1) legal research concerning post-verdict motions and potential 

appellate issues in Marshall v. Catholic Health Initiatives, Inc., Civil 

Action No. 11-CI-00972, in the 27th Judicial Circuit, Laurel Circuit 

Court Division II, of the Commonwealth of Kentucky by March 31, 

2015; 

(2) preparing responses to multiple motions for summary 

judgment by April 2, 2015 in Cause No. 2014-CVT000757-D3, Trevino, 
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 3

et al. v. Union Pumping, L.P., et al., pending in the 341st Judicial 

District Court of Webb County, Texas;

(3) extensive legal research to facilitate revision of pleadings 

and discovery in Cause No. 13-2531, Carlton v. Media Nation Outdoor, 

LLC, et al., in the 22nd Judicial District Court of Hays County, Texas

by April 9, 2015; and

(4) family and religious commitments over the extended Holy 

Week holiday (April 3, 2015 through April 5, 2015). 

III.

In light of the foregoing, Appellants respectfully request a 21-day 

extension of time, from April 15, 2015 to May 6, 2015, to file their reply 

brief. 

IV.

This extension is not sought for purposes of delay. It is requested 

because of the above-mentioned circumstances, along with the regular 

interruptions of a busy law practice. 

WHEREFORE, PREMISES CONSIDERED, Appellants Maribel 

Ambriz Martinez, Guadalupe Mota, and Rosa Nelly Trevino respectfully 

request that this motion be granted and that the time for filing their 
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 4

brief be extended by 21 days from April 15, 2015 to May 6, 2015. 

Appellants also respectfully pray for such other and further relief to 

which they may be entitled.

Respectfully submitted,

WATTS GUERRA, LLP

Michael J. Murray 

State Bar No. 24007721

mmurray@wattsguerra.com

Francisco Guerra IV

State Bar No. 00796684

fguerra@wattsguerra.com

Shalimar S. Wallis

State Bar No. 24033191

swallis@wattsguerra.com

300 Convent Street, Suite 100

San Antonio, Texas 78205

(210) 527-0500 (telephone)

LAW OFFICE OF MICHAEL MILLER

Michael Miller

State Bar No. 00788060

mmiller@michaelmillerlaw.com

926 Chulie Drive

San Antonio, Texas 78216

(210) 225-6666 (telephone)

 /s/ Michael J. Murray . 

Michael J. Murray 

ATTORNEYS FOR APPELLANTS
Appellants’ Second Unopposed Motion for Extension of Time to File Reply Brief 5

CERTIFICATE OF CONFERENCE

Pursuant to Texas Rule of Appellate Procedure 10.1(a)(5), on April 

10, 2015, the undersigned conferred with Ms. Elizabeth Conry Davidson, 

attorney for Appellee. Ms. Davidson advised that Appellee does not 

oppose the relief Appellants seek by this motion. 

 /s/ Michael Murray .

Michael J. Murray 

CERTIFICATE OF SERVICE

I certify that the foregoing document was electronically filed with 

the Clerk of the Court using the electronic filing system of the Court. I 

also certify that a true and correct copy of the foregoing was served via 

e-service or e-mail on the following counsel of record on April 10, 2015:

Carl J. Kolb

CARL J. KOLB, P.C.

926 Chulie Drive

San Antonio, Texas 78216

Elizabeth Conry Davidson

Attorney at Law

926 Chulie Drive

San Antonio, Texas 78216

Counsel for Appellee Alfredo Gonzalez

 /s/ Michael J. Murray .

Michael J. Murray