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No. 05-16-00332-CV 

IN THE FIFTH DISTRICT COURT OF APPEALS 

AT DALLAS, TEXAS 

IN RE ANTHONY R. SANDERS, 

RELATOR 

Original Proceeding Arising out of the 

296TH Judicial District Court 

of Collin County, Texas 

Cause No. 296-56252-2012 

Honorable John Roach, Jr. Presiding 

REAL PARTY IN INTEREST'S SECOND MOTION FOR EXTENSION OF TIME TO 

FILE PAST DUE RESPONSE TO PETITION FOR WRIT OF MANDAMUS 

Respectfully submitted, 

By:~ CASEY T. BOYD 

State Bar No. 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 

COUNSEL FOR REAL PARTY IN INTEREST 

EDV ANIA SANDERS 

ACCEPTED

05-16-00332-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

4/21/2016 4:39:35 AM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 4/21/2016 4:39:35 AM LISA MATZ Clerk
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REAL PARTY IN INTEREST'S SECOND MOTION FOR 

EXTENSION OF TIME TO FILE PAST DUE RESPONSE 

TO PETITION FOR WRIT 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 of Mandamus. 

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 of Mandamus, 

if any, 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. That was her first request for extension of time 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, if any, 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 of Mandamus, Real Party in Interest did in fact file 

her Response with the Court. Her Response was filed with the Court four (4) 

hours late. 

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Counsel for Real Party in Interest relies 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 of time: 

Counsel for Real Party in Interest was unable to properly convert the 

Response to text searchable portable document format per the 

applicable Rules of Court prior 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 

convert the Response to text searchable portable document format. 

Counsel for Real Party in Interest seeks this extension of time to file the past 

due Response so that this Court can be aided in its analysis of the issues presented. 

This request is not sought for delay but so that justice may be done. 

The undersigned has not conferred with Relator's counsel of record, 

Georganna Simpson, prior to the filing of this 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 FOR RELIEF 

For the reasons set forth above, Real Party in Interest requests that this Court 

grant this Second Motion to Extend Time to File Past Due Response to Petition for 

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Writ of Mandamus and extend the Deadline for Filing the Real Party in Interest's 

Response up to and including April 21, 2016. 

Real Party in Interest requests all other relief to which she may be entitled. 

Respectfully submitted, 

THE SHAPIRO LAW FIRM 

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 Bar No. 24059477 

COUNSEL FOR REAL PARTY IN 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 of Mandamus. 

CASEY T. BOYD 

Counsel for Real Party in Interest 

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CERTIFICATE OF SERVICE 

I certify that on April 21, 2016, I served a copy of this motion to the 

following counsel and parties by electronic mail or via facsimile. 

Georganna L. Simpson 

Counsel for Relator 

Beth M. Hearn 

Counsel for Relator 

The Honorable John Roach, Jr. 

296th Judicial District Court 

Collin County, Texas 

Respondent 

COUNSEL FOR REAL PARTY IN INTEREST 

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