No. 03-14-00795-CV 

Jennifer Samaniego,

Court of Appeals

for the Third District

Austin, Texas

Appellant,

v.

Alieda Silguero, et al.,

Appellees.

Samaniego’s Motion for 32-day Extension 

of Deadline to File Appellant’s Opening Brief

Appellant Jennifer Samaniego moves for a 30-day extension of the 

deadline to file her brief. This is her first motion for an extension; the 

brief was due on April 2, 2015, and the requested extension would, because of a weekend, make the new deadline May 4, 2015.

Samaniego’s counsel did not file Samaniego’s brief because he 

didn’t realize that the clock had started ticking. Samaniego’s counsel 

spends most of his time in the First and Fourteenth Courts of Appeal 

and the Supreme Court. The routine in the First and Fourteenth 

Courts is that once the record is complete, the clerk sends the parties a 

notice of the deadline for the appellant’s brief. The Supreme Court 

issues similar notices once a petition has been filed or when it orders 

briefing on the merits. Samaniego’s counsel received the Court’s notice that the clerk’s record had been filed, but the Court’s notice 

didn’t state a briefing deadline. He believed that omitting the deadline 

from the notice meant that the Court was still waiting for something 

from the trial court or the county clerk. He was wrong, and he apologizes for the delay that error has caused the Court.

ACCEPTED

03-14-00795-CV

4907596

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/15/2015 5:51:28 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 4/15/2015 5:51:28 PM JEFFREY D. KYLE Clerk
The error that lies solely at the feet of Samaniego’s counsel 

shouldn’t be visited upon Samaniego herself. It was a misunderstanding, an inadvertent failure to recognize that routines not prescribed by 

the Rules aren’t necessarily going to be uniform among the state’s 

many appellate courts. Her counsel intended to cause no delay, and 

the delay has caused no prejudice that Samaniego or her counsel can 

see. This inadvertence, Texas’s preference for deciding cases on the 

merits of the arguments rather than procedural rulings, and the lack of 

prejudice to the appellee show good cause for the Court to extend the 

deadline

Samaniego prays that the Court make May 2, 2015, the deadline for 

her to file her brief.

Respectfully submitted,

The Olson Firm PLLC

/s/ Leif A. Olson

Leif A. Olson

leif@olsonappeals.com

State Bar No. 24032801

PMB 188

4830 Wilson Road, Suite 300

Humble, Texas 77396

(281) 849-8382

Counsel for Samaniego

Case 03-14-00795-CV, Samaniego v. Salguero Page 2 of 3

Samaniego’s Motion for 32-Day Extension
Certificate of Conference

On April 15, 2015, Nadia Ramkissoon, counsel for appellee Alieda 

Silguero, informed me that she opposes the requested extension.

/s/ Leif A. Olson

Certificate of Service

On April 15, 2015, I served this Samaniego’s Motion for 32-day Extension of Deadline to File Appellant’s Opening Brief by electronic service upon:

Nadia Ramkissoon

nadia.ramkissoon@farmersinsurance.com

Clark, Price & Trevino

1701 Directors Blvd., Suite 920

Austin, Texas 78744

Counsel for Appellee

Alieda Silguero

/s/ Leif A. Olson

Case 03-14-00795-CV, Samaniego v. Salguero Page 3 of 3

Samaniego’s Motion for 32-Day Extension