Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 1 

NO. 04-14-00564-CV

IN THE COURT OF APPEALS

FOURTH DISTRICT OF TEXAS

SAN ANTONIO, TEXAS

 IN THE ESTATE OF WADE R. BEDELL, JR. DECEASED 

APPELLEE’S UNOPPOSED SECOND

MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE FOURTH COURT OF APPEALS:

Appellee Robyn Joan Zalewa asks the Court to extend the time for 

filing her brief to and including April 23, 2015, and in support of this 

motion shows:

Date of Judgment, Number and Style of Case

1. This is an appeal from a final judgment signed on April 1, 2014, 

by the Honorable Tom Rickhoff, Probate Court No. 2, Bexar County, Texas, 

in Cause No. 2013-PC-0636, styled In the Estate of Wade R. Bedell, Jr., 

Deceased.

Perfection of Appeal

2. Appellant Deborah Bedell filed her notice of appeal with this 

Court on August 7, 2014. 

ACCEPTED

04-14-00564-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

4/13/2015 3:16:10 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 4/13/2015 3:16:10 PM KEITH E. HOTTLE Clerk
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 2

Record

3. The clerk’s record was filed with this Court on August 7, 2014, 

with subsequent supplemental clerk’s records that were filed on August 27, 

2014, September 9, 2014, October 9, 2014, December 31, 2014, and January 

12, 2015. The reporter’s record was filed with this Court on August 14, 

2014, and a supplemental reporter’s record filed on February 18, 2015.

Current Deadline

4. Appellant filed her amended brief on February 10, 2015. After 

having received one previous extension, Appellee’s brief is due on April 13, 

2015.

Length of Extension Sought

5. Appellant requests a 10-day extension to April 23, 2015.

Facts Reasonably Explaining Need for Extension

During the last thirty (30) days, the undersigned attorney who has the 

primary responsibility to prepare Appellee’s Brief, has been involved in the 

following matters, which have hampered his ability to prepare Appellant’s 

Brief, as follows:

• Preparation of appellant’s reply brief in Cause No. 04-14-00903-CV, 

Lightning Oil Company v. Anadarko E&P Onshore LLC fka 

Anadarko E&P Company; Fourth Court of Appeals, San Antonio, 

Texas;

• Preparation of response to petition for writ of mandamus in Cause 

No. 15-0109; In re Gilbert L. Mathews and Lucifer Lighting 

Company; Supreme Court of Texas, Austin, Texas;
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 3

• Preparation of post-trial motions and briefs in Cause No. 29842; 

Knighthawk, LLC, Series G v. B&P Development and Chad H. Foster, 

Jr., 83rd Judicial District Court, Val Verde County, Texas; and

• Preparation of petitioner’s brief on the merits in Cause No. 14-0223; 

Methodist Healthcare System of San Antonio, LTd., LLP dba 

Northeast Methodist Hospital v. Thomas Dewey; Supreme Court of 

Texas, Austin, Texas.

Second Request for Extension

6. This is the second request for an extension of time to file 

Appellee’s brief.

Request for Relief

7. For all these reasons, Appellee Robyn Joan Zalewa respectfully 

asks this Court to grant this motion and to extend the date for filing her 

brief for a period of 10 days, to April 23, 2015.

Respectfully submitted,

/s/ Robinson C. Ramsey 

ROBINSON C. RAMSEY

State Bar No. 16523700

Email: rramsey@langleybanack.com

JAMES W. CARTER, IV

State Bar No. 24006333

Email: jcarter@langleybanack.com

LANGLEY & BANACK, INC.

Trinity Plaza II, Suite 900

745 E. Mulberry Avenue

San Antonio, Texas 78212

Telephone: 210. 736.6600

Telecopier: 210. 735.6889

ATTORNEYS FOR APPELLEE

ROBYN ZALEWA
Appellee’s Unopposed Second Motion for Extension of Time to File Brief Page 4

CERTIFICATE OF CONFERENCE

Appellee’s attorney has conferred with Appellant’s counsel, John 

Wennermark, who does not oppose this motion.

/s/Robinson C. Ramsey

ROBINSON C. RAMSEY

CERTIFICATE OF SERVICE

A true and correct copy of the foregoing document was served upon 

the following counsel for Appellant:

John D. Wennermark

State Bar No. 21177000

Email: johnwennermark@hotmail.com

1924 N. Main Avenue

San Antonio, Texas 78212

Telephone: 210.226.6262

Telecopier: 210.225.1351

on this 13th day of April, 2015.

/s/ Robinson C. Ramsey 

ROBINSON C. RAMSEY