No. 04-15-00127CV 

IN THE COURT OF APPEALS 

FOR THE 4THJUDICIAL DISTRICT OF TEXAS 

AT SAN ANTONIO 

EL CABALLERO RANCH, INC. 

AND LAREDO MARINE, L.L.C., Appellants 

V. 

GRACE RIVER RANCH, LLC, Appellee 

Appealed from 

the 218thDistrict Court of 

La Salle County, Texas 

UNOPPOSED MOTION TO 

EXTEND TIME TO FILE APPELLEE'S BRIEF 

MOORMAN TATE HALEY 

UPCHURCH & YATES, LLP 

By: STEVEN C. HALEY 

State Bar No. 08741900 

207 E. Main St./P.O. Box 1808 

Brenham, Texas 77834-1808 

Telephone: (979) 836-5664 

Telecopier: (979) 830-0913 

shaley@moormantate.com 

Attorney for Appellee, 

Grace River Ranch, LLC 

{18705.43065-00384445.DOCX} 

ACCEPTED

04-15-00127-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

5/27/2015 8:16:24 AM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 05/27/2015 8:16:24 AM KEITH E. HOTTLE Clerk
No. 04-15-00127CV 

IN THE COURT OF APPEALS 

FOR THE 4THJUDICIAL DISTRICT OF TEXAS 

AT SAN ANTONIO 

EL CABALLERO RANCH, INC. 

AND LAREDO MARINE, L.L.C., Appellants 

V. 

GRACE RIVER RANCH, LLC, Appellee 

Appealed from 

the 218" District Court of 

La Salle County, Texas 

UNOPPOSED MOTION TO 

EXTEND TIME TO FILE APPELLEE'S BRIEF 

TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS: 

Grace River Ranch, LLC (Grace River), Appellee in this appeal and Plaintiff 

below, respectfully files this, its Unopposed Motion to Extend Time to File 

Appellee's Brief, and in support of same would show this Court the following: 

2 

{18705.43065-00384445.DOCX} 
Statement of Facts 

1. Summary Judgment in Trial Court. This case originated in the trial court 

as an action styled Grace River Ranch, LLC v. El Caballero Ranch, Inc. a/k/a El 

Caballero Ranch, LLC and Laredo Marine, LLC v. County of La Salle; No. 13-04- 

00108-CV, 218thDistrict Court, La Salle County, Texas. 

Motion to Extend Time to File Brief 

2. Deadline to File Appellees' Brief. The deadline to file Appellees' Brief is 

May 29, 2015. 

3. Length of Extension Sought. An extension is sought to file Appellee's 

Brief through June 29, 2015. 

4. No Previous Extension Sought by Appellee. Appellee has sought no 

previous extension of Appellee's briefing deadline. 

5. Reason that Extension is Sought. This extension is sought because of the 

busy trial schedule of counsel for Appellee. Counsel has two appellate briefs 

which are being handled at the same time which is an unusual event. Counsel's 

secretary has been out for three weeks due to a severe illness and hospitalization 

which has placed things generally behind on all fronts. This extension is not 

sought for delay but to allow due consideration of Appellants' Brief and a detailed 

response to it. 

3 

(18705.43065-00384445.DOCX) 
WHEREFORE, PREMISES CONSIDERED, Appellee requests an 

extension of the within in which to file Appellee's Brief until June 29, 2015. 

Respectfull ubmitted, 

1V10 ORMA A HALEY 

UPCHURCH & YATES, LLP 

By: 

STEVEN C. HALEY 

State Bar No. 08741900 

207 East Main 

P.O. Box 1808 

Brenham, Texas 77834- :08 

Telephone: (979) 83. 664 

Telecopier: (979) 830-0913 

shaley@moormantate.corn 

MONTEZ & PATTERSON 

John H. Patterson, Jr. 

State Bar No. 24027716 

Thornton Plaza 

508 Thorton, Suite 4 

Cotulla, Texas 78014 

Telephone: (830) 483-5191 

Telecopier: (830) 483-5192 

john@montezandpatterson.com 

Attorneys for Appellee, 

GRACE RIVER RANCH, L.L.C. 

4 

{18705.43065-00384445.DOCX) 
CERTIFICATE OF SERVICE 

I, Steven C. Haley, do hereby certify that on the-2-1-61 day of May, 2015, I 

served a true and correct copy of the foregoing Motion to Extend Time to File 

Appellee's Brief to the following, deposited in a post-paid, depository under the 

care and custody of the United States Postal Service, duly addressed to such party 

at the address stated, by certified mail, return receipt requested, facsimile, e-mail, 

and/or hand-delivery. 

Annalyn G. Smith 

Schmoyer Reinhard, LLP 

17806 I-10W, Ste. 400 

San Antonio, Texas 78257 

E-mail: asmith@ar-11p.com 

Kimberly S. Keller 

Keller Stolarczyk PLLC 

234 West Bandera Road, No. 120 

Boerne, Texas 78006 

E-mail: kim@kellsto.com 

Donato D. Ramos 

Donato D. Ramos, Jr. 

Law Offices of Donato D. Ramos 

6721 McPherson 

P.O. Box 452009 

Laredo, Texas 78045 

donatoramosjr@ddrlex.com 

STEVEN C. HALEY 

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{18705.43065-00384445DOCX} 
CERTIFICATE OF CONFERENCE 

I hereby certify that on May 1$,-20-1-5, nferred with opposing counsel, 

Kimberly S. Keller, who indicate 'she does not op.ose he foregoing Motion to 

Extend Time to File Appellee's grief. 

STEVEN C. HALEY 

6 

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