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No. 04-14-00913-CV

IN THE

FOURTH COURT OF APPEALS

SAN ANTONIO

DAVID MEDRANO,

Appellant, 

v .

FIDELITY NATIONAL TITLE INSURANCE COMPANY, SUCCESSOR BY

MERGER LAWYERS TITLE INSURANCE CORPORATION, BARCLAYS

CAPITAL REAL ESTATE INC. D.B.A. HOMEQ, AS SERVICING AGENT

FOR DEUTSCHE BANK NATIONAL TRUST COMPANY

AS TRUSTEE, ET AL,

Appellees. 

ON APPEAL FROM THE 37TH JUDICIAL DISTRICT COURT

BEXAR COUNTY, TEXAS

CAUSE NUMBER 2008-CI-00027

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE

APPELLEE FIDELITY NATIONAL TITLE INSURANCE COMPANY’S 

BRIEF 

TO THE HONORABLE COURT OF APPEALS:

Appellee, Fidelity National Title Insurance Company, Successor by Merger 

with Lawyers Title Insurance Corporation (“Fidelity”), respectfully files this 

unopposed motion for extension of time to file its Appellee’s brief.

ACCEPTED

04-14-00913-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

10/19/2015 2:52:44 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 10/19/2015 2:52:44 PM KEITH E. HOTTLE Clerk
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1. Appellant David Medrano filed Appellant’s brief on September 17, 

2015, after obtaining three extensions of the deadline to file his brief.

2. The current deadline for filing Appellees’ brief is October 19, 2015.

3. Fidelity seeks a 30-day extension until November 18, 2015 of the 

deadline in which to file its brief.

4. This motion is unopposed. This is Fidelity’s first request for an 

extension of its briefing deadline.

5. The Court has also granted a thirty-day extension to Appellee 

Deutsche Bank National Trust Company, Trustee in which to file its brief. 

6. The following grounds provide good cause for extending the time to 

file the brief. Counsel for Fidelity has been and continues to be engaged in other 

litigation with imminent deadlines that will prevent them from completing 

Appellees’ brief before the deadline, including, but not limited to, the following:

• Preparation for jury trial in 2012-CI-13430, Stephen Torres v. City of 

San Antonio et al., in the 224th District Court, Bexar County, Texas. 

Jury trial was set for October 19, 2015. On Friday, October 16, 2015, 

counsel received an Order from the Court granting a motion for 

summary judgment on the case. However, this was not before counsel 

was required to prepare for the jury trial that was expected to last one 

to two weeks.
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• Preparation and attendance at a mediation of Cause No. 2014-CI01756; Alamo Fireworks, Inc. v. Mr. W Fireworks, Inc.; In the 150th

Judicial District Court, Bexar County, Texas. The mediation occurred 

on October 7, 2015.

7. This motion is not filed for the purpose of delay, but to allow

Fidelity’s counsel adequate time to prepare its brief.

For these reasons, Appellee, Fidelity National Title Insurance Company, 

Successor by Merger with Lawyers Title Insurance Corporation, respectfully 

requests the Court grant an extension of time to file its Appellee’s brief until 

November 18, 2015.

Respectfully submitted,

By: /s/ Aaron M. Barton

Fred R. Jones

Texas Bar No. 10886700

jones@goodelaw.com

Aaron M. Barton 

Texas Bar No. 24059430

barton@goodelaw.com

Goode, Casseb, Jones

Riklin, Choate & Watson, P.C.

P.O. Box 120480

San Antonio, Texas 78212

Telephone: (210) 733-6030

Facsimile: (210) 733-0330

Attorneys for Fidelity National Title 

Insurance Company, Successor by Merger 

with Lawyers Title Insurance Corporation
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CERTIFICATE OF CONFERENCE

I, Aaron M. Barton, certify that I conferred with counsel for Appellant and 

counsel for all other Appellees on October 19, 2015, and counsel for all parties 

stated they are unopposed to the requested extension.

/s/ Aaron M. Barton

Aaron M. Barton

CERTIFICATE OF SERVICE

I hereby certify that on October 19, 2015, a true and correct copy of the 

foregoing was sent by facsimile, as follows:

Gregory T. Van Cleave

The Law Office of

Albert W. Van Cleave, III PLLC

1520 W. Hildebrand

San Antonio, TX 78201

Thomas E. Quirk

Aaron & Quirk

Law Offices of Aaron & Quirk

8700 Crownhill Boulevard, Suite 600

San Antonio, Texas 78209

Valerie Henderson

Kari Robinson

Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C.

1301 McKinney Street, Suite 3700

Houston, Texas 77010

/s/ Aaron M. Barton

Aaron M. Barton