No. 04-15-00070-CV

In The Fourth Court Of Appeals 

San Antonio, Texas 

SKYLINE EMS, INC. AND JUAN “JOHNNY” CORDERO

Appellants, 

v.

AR CONCEPTS, INC. 

Appellee. 

ON APPEAL FROM THE 224th DISTRICT COURT, Bexar COUNTY, TEXAS 

TRIAL COURT CAUSE NO. 2014CI15618 

APPELLANTS’ UNOPPOSED FIRST MOTION TO EXTEND TIME TO 

FILE APPELLANTS’ BRIEF 

RYAN LAW FIRM, LLP 

Doug Sigel 

Texas Bar No. 18347650 

100 Congress Avenue, Suite 950 

Austin, Texas 78701 

Telephone: (512) 459-6600 

Facsimile: (512) 459-6601 

Skyline EMS, INC. And Juan “Johnny” Cordero

ACCEPTED

04-15-00070-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

4/8/2015 10:47:50 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 4/8/2015 10:47:50 AM KEITH E. HOTTLE Clerk
Identity of Parties and Counsel

Appellants/Defendants: Defendants/Appellants’ Appellate 

Counsel:

RYAN LAW FIRM, LLP

Doug Sigel

Texas Bar No. 18347650

100 Congress Avenue, Suite 950

Austin, Texas 78701

Telephone: (512) 459-6600

Facsimile: (512) 459-6601

Doug.Sigel@ryanlawllp.com

Appellee/Plaintiff: Plaintiff/Appellee’s Appellate Counsel:

David Henry Cavazos IV

The Cavazos Law Firm PC

609 N. Laurel Street

El Paso, Texas 79903

Telephone: (915) 227-7515

Facsimile: (915) 808-2558

davidcavazos@davidcavazos.com
TO THE HONORABLE FOURTH COURT OF APPEALS:

Pursuant to Tex. R. App. P. 10.1 and 38.6(d), the Appellants, Skyline EMS, 

Inc. & Juan “Johnny” Cordero file this Unopposed First Motion to Extend Time to 

File Appellants’ Brief.

The Appellants’ Brief is currently due on April 13, 2015.

Counsel for Appellants request a 30-day extension of time to file its 

Appellants’ Brief, making the brief due on May 13, 2015. This is the first request 

for extension of time to file the Appellants’ Brief.

Counsel for Appellants 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 requested extension:

• The undersigned counsel will be traveling out-of-state on firm-related 

matters on April 8, 2015.

• The undersigned counsel for Fitness International, LLC, is preparing for a 

deposition in the case, styled Fitness International, LLC, v. Glenn Hegar, 

Comptroller of Public Accounts of the State of Texas, and Ken Paxton, Attorney 

General of The State of Texas; Cause No. D-1-GN-14-003869; in the 98th Judicial 

District Court of Travis County, Texas, to be held on April 9, 2015.

• The undersigned counsel for Kroger Texas, L.P., is preparing for a hearing

in the case, styled Kroger Texas, L.P., v. Glenn Hegar, Comptroller of Public 
Accounts of the State of Texas, and Ken Paxton, Attorney General of The State of 

Texas; Cause No. D-1-GN-14-001929; in the 201st Judicial District Court of Travis 

County, Texas, to be held on April 13, 2015.

Counsel for Appellants’ seeks this extension of time to be able to prepare a 

cogent and succinct brief to aid this Court in its analysis of the issues presented. 

Given the other time commitments imposed on counsel, it will not be possible to 

prepare the Appellants’ Brief by April 13, 2015. This request is not sought for delay 

but so that justice may be done.

The undersigned has conferred with David Henry Cavazos IV, counsel for the 

Plaintiff/Appellee, and he has indicated that he does not oppose this motion.

All facts recited in this motion are within the personal knowledge of the 

counsel signing this motion; therefore no verification is necessary under Texas Rule 

of Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellants request that this Court grant this 

Unopposed First Motion to Extend Time to File Appellants’ Brief and extend the 

deadline for filing the Appellants’ Brief up to and including May 13, 2014. 

Appellants request all other relief to which they may be entitled.
Respectfully submitted,

RYAN LAW FIRM, LLP

/s/ Doug Sigel

Doug Sigel

Texas Bar No. 18347650

100 Congress Avenue, Suite 950

Austin, Texas 78701

Telephone: (512) 459-6600

Facsimile: (512) 459-6601

Doug.Sigel@ryanlawllp.com

Attorney For Appellants

Skyline EMS, INC. and Juan “Johnny” 

Cordero

CERTIFICATE OF CONFERENCE

Pursuant to Tex. R. App. P. 10.1(5), I certify that the undersigned conferred

with opposing counsel, David Henry Cavazos IV, on April 8, 2015, and Mr. Cavazos 

is not opposed to this motion.

/s/ Doug Sigel

Doug Sigel

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing Appellants’ Unopposed First Motion to 

Extend Time to File Appellants’ Brief was served on Appellee, AR Concepts, Inc., 

through counsel of record, David Henry Cavazos IV, The Cavazos Law Firm PC, 

609 N. Laurel Street, El Paso, Texas 79903, by electronic mail and electronic service 

on April 8, 2015.

/s/ Doug Sigel

Doug Sigel