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.

O N A PPEAL FROM THE 224 th DISTRICT C OURT , Bexar C OUNTY , T EXAS

T RIAL C OURT C AUSE N O

. 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 CLERKIdentity of Parties and Counsel

Appellant s /Defendant s : Defendant s /Appellant s ’ 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 .comTO THE HONORABLE FOURTH COURT OF APPEALS:

Pursuant to Tex. R. App. P. 10.1 and 38.6(d), the Appellant s , Skyline EMS,
Inc. & Juan “Johnny” Cordero file this Unopposed First Motion to Exten d Time to File Appellant s ’ Brief. The Appellant s ’ Brief is currently due on April 1 3 , 2015
. Counsel for Appellants request a 30

- day extensio n of time to file its Appellant s ’ 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

- rela ted

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

- 1 4

- 003869 ; in the 98 th 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 K

roger Texas, L.P. , v. Glenn Hegar, Comptroller of PublicAccounts of the State of Texas, and Ken Paxton, Attorney General of The State of

Texas ; Cause No. D

- 1

- GN

- 14

- 00 1929 ; 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

prep are the Appellant s ’ 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 no t 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 rel ief 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 Appellant s Skyline EMS, INC. and Juan “Johnny” Cordero
CERTIFICATE OF CONFERENCE Pursuant to Tex. R. App. P. 10.1(5), I certify that the undersigned confer red with opposing counsel, David He n ry 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 Appellant s ’ Brief was s erved 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