No. 04-14-00620-CV 

 

IN THE COURT OF APPEALS

FOR THE FOURTH DISTRICT OF TEXAS

AT SAN ANTONIO

 

 

ROSA OBREGON PEREZ, ET AL. 

 Appellants, 

v.

THE GOODYEAR TIRE & RUBBER COMPANY, 

 Appellee 

 

On Appeal from Cause No. 26130, In the 83rd Judicial District Court of 

Val Verde County, Texas, Honorable Robert E. Cadena, Presiding 

 

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANTS’ REPLY BRIEF 

 

TO THE HONORABLE COURT OF APPEALS: 

 Appellants ROSA OBREGON PEREZ, RICARDO O. PEREZ, 

Individually and as Next Friend of ROSA ELIA PEREZ, MARIA 

PEREZ JALOMUS, JUAN JOSE PEREZ, JULIO PEREZ, JR., and 

FERNANDO PEREZ, respectfully request that the time to file their 

reply brief be extended until 20 days after either Appellee files its 

amended brief or February 23, 2015, whichever is earlier. This is their 

ACCEPTED

04-14-00620-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

1/30/2015 8:36:33 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 01/30/2015 8:36:33 AM KEITH E. HOTTLE Clerk
2

first request for an extension of time to file their reply brief. The 

requested extension is unopposed. 

I. 

This appeal arises from the July 31, 2014 Final Judgment 

rendered by the trial court. The notice of appeal was filed by mail on 

August 26, 2014, and received by the trial court on September 2, 2014. 

The Clerk’s Record was filed on October 15, 2014. Appellants’ brief was 

filed on December 14, 2014. Appellee filed its brief on January 21, 

2015. Appellants’ reply brief is currently due to be filed on or before 

February 10, 2015. However, that date could change depending upon 

whether Appellee files an amended brief.

Due to the sealed record that is part of the appellate record in this 

appeal, Appellee also requested that its attorneys be permitted to 

review the sealed record and, if necessary, file an amended brief. On

January 23, 2015, this Court granted the motion, permitting access to 

the sealed record and until February 23, 2015 to file an amended brief, 

if they choose to do so. Appellants respectfully request that the 

deadline for filing their reply brief be extended until 20 days after 

either Appellee files an amended brief or February 23, 2015, whichever 

is earlier.

 

 
3

II. 

This extension is not sought for purposes of delay, but to limit the 

amount of unnecessary briefing that is filed with this Court. Under the 

current deadlines, Appellants would be required to file a reply brief 

responding to the arguments raised in Appellee’s brief by February 10, 

2015. However, due to the Court’s order, those arguments could change 

should Appellee file an amended brief, thus necessitating a second reply 

brief by Appellants. In order to ensure that Appellee has presented all 

of its arguments before Appellants reply, Appellants respectfully 

request that the deadline for filing their reply brief be extended until 20 

days after either an amended brief has been filed or the time for filing

one has passed, whichever is earlier. 

III.

CERTIFICATE OF CONFERENCE 

The undersigned conferred with counsel for Appellee, and 

Appellee does not oppose the requested extension. 

 

WHEREFORE, PREMISES CONSIDERED, Appellants ROSA 

OBREGON PEREZ, RICARDO O. PEREZ, Individually and as Next 

Friend of ROSA ELIA PEREZ, MARIA PEREZ JALOMUS, JUAN 

JOSE PEREZ, JULIO PEREZ, JR., and FERNANDO PEREZ, 

respectfully request that the Court grant their motion for extension of 
4

time in which to file their reply brief and extend the deadline until 20

days after either Appellee files an amended brief or February 23, 2015, 

whichever is earlier, and grant such other and further relief to which 

they are justly and equitably entitled.

Respectfully submitted,

_/s/ William G. Neumann__________

William G. Neumann, Jr.

SB 14931000 

HAGOOD & NEUMANN

1520 E. Highway 6

Alvin, Texas 77511

Telephone: 281.331.5757

Fax: 281.331.1105

Counsel for Appellants

 
5

CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of this document will 

be sent to the following parties of record:

J. Michael Myers

NATHAN HOWELL SMITH & LEE, PLLC

10001 Reunion Place, Suite 600

San Antonio, Texas 78216

Attorneys for Appellee

The Goodyear Tire & Rubber Company

_/s/ William G. Neumann__________

William G. Neumann, Jr.