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NO. 04-14-00740-CV

IN THE COURT OF APPEALS 

FOR THE FOURTH JUDICIAL DISTRICT OF TEXAS 

AT SAN ANTONIO 

ART REYNA, 

Appellant, 

v.

IRENE BALDRIDGE AND KATHY HILL, 

Appellees. 

ON APPEAL FROM THE 285th JUDICIAL DISTRICT COURT 

BEXAR COUNTY, TEXAS 

TRIAL COURT NO. 2014-CI-03985 

THE HONORABLE JUDGE CATHLEEN M. STRYKER PRESIDING 

UNOPPOSED MOTION TO EXTEND TIME TO FILE 

APPELLANT’S REPLY BRIEF 

TO THE HONORABLE JUSTICES OF THE COURT: 

 Under Texas Rules of Appellate Procedure 10.5(b)(1) and 38.6(d), Appellant 

Art Reyna, referred to as Appellant, respectfully moves the Court to extend the time 

for filing Appellant’s Reply Brief. As good cause, Appellant respectfully shows the 

Court the following: 

ACCEPTED

04-14-00740-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

4/15/2015 11:14:54 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 04/15/2015 11:14:54 AM KEITH E. HOTTLE Clerk
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1. Appellees Irene Baldridge and Kathy Hill filed their Appellees’ Brief on 

March 26, 2015. 

2. Under Texas Rule of Appellate Procedure 38.6(c), Appellant’s Reply Brief is 

currently due on or before April 15, 2015. 

3. Appellant requests that the Court extend the time to file Appellant’s Reply 

Brief seven (7) days. A seven (7) day extension would make the Appellant’s Reply 

Brief due on April 22, 2015. 

4. In support of the requested extension, Appellant would show that Appellees 

cited numerous lengthy cases in their Appellees’ Brief that require analysis to 

prepare a proper reply, in addition to analysis of recent cases decided or pending 

under Tex. Civ. Prac. & Rem. Code Chapter 27, which serves as the basis of this 

appeal. 

5. In addition, counsel for Appellant, Ronald B. Prince and Floyd Steven 

Contreras, had commitments during the time to reply that required their time and 

attention and interfered with preparation of Appellant’s Reply Brief by the current 

deadline, including the following:

Preparation for trial and trial in Cause No. 21DC1401864, Troy Capital, LLC 

v. Elvira Eardley-Thrash, in Justice Court, Precinct 2, Bexar County, which took 

place on April 14, 2015.
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6. This is Appellant’s first request for an extension of time to file Appellant’s

Reply Brief. Appellant seeks this extension not solely for delay, but so that justice 

may be done.

7. As reflected in the Certificate of Conference below, counsel for Appellees 

indicated that they are unopposed to this motion.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant Art Reyna

respectfully requests that the Court grant a seven (7) day extension of time to file 

Appellant’s Reply Brief, extending the time to file Appellant’s Reply Brief until

April 22, 2015. 

Appellant further prays for such other relief to which he may be entitled. 

Respectfully submitted,

PRINCE CONTRERAS PLLC

417 San Pedro Avenue

San Antonio, Texas 78212

Tel: (210) 227-7821

Fax: (210) 225-4469

info@princecontreras.com 

ATTORNEYS FOR ART REYNA

_/s/ Floyd Steven Contreras_____________

RONALD B. PRINCE

State Bar No. 16329300

ron@princecontreras.com

FLOYD STEVEN CONTRERAS

State Bar No. 24075339

floyd@princecontreras.com
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CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with Edward P. Cano and Darby Riley, 

counsel for Appellees, regarding our Motion to Extend Time to File Appellant’s 

Reply Brief. 

Both Mr. Cano and Mr. Riley indicated that they are unopposed to our motion.

_/s/ Floyd Steven Contreras_____________

RONALD B. PRINCE

FLOYD STEVEN CONTRERAS 

CERTIFICATE OF SERVICE

I hereby certify that on the 15

th day of April, 2015, a true and correct copy of 

the foregoing Unopposed Motion to Extend Time to File Appellant’s Reply Brief 

was served on the following counsel of record electronically through the electronic 

filing manager:

Mr. Edward P. Cano

201 W. Poplar St.

San Antonio, Texas 78212

Tel: (210) 223-1099

Fax: (210) 212-5653

edcanoattorney@sbcglobal.net Attorney for Appellees

Mr. Darby Riley 

RILEY & RILEY

320 Lexington Avenue

San Antonio, Texas 78215

Tel: (210) 225-7236

Fax: (210) 227-7907

darbyriley@rileylawfirm.com Attorney for Appellees

_/s/ Floyd Steven Contreras_____________

RONALD B. PRINCE

FLOYD STEVEN CONTRERAS