CAUSE NUMBER 03-15-00128-CV

IN THE COURT OF APPEALS 

FOR THE THIRD COURT OF APPEALS DISTRICT 

AUSTIN, TEXAS 

TEDDE R. BLUNCK, 

Appellant, 

V.

CATHY A. BLUNCK, 

Appellee. 

ON APPEAL FROM THE 22ND DISTRICT COURT, HAYS COUNTY, TEXAS 

TRIAL COURT CAUSE NO. 11-1217 

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANT’S BRIEF 

TEDDE R. BLUNCK, PRO SE

502 QUITMAN STREET 

P O BOX 1152 

PITTSBURG, TEXAS 75686 

TELEPHONE: (903) 855-8460 

TELECOPIER: (903) 855-8465 

E-MAIL: TBLUNCK@YAHOO.COM 

ACCEPTED

03-15-00128-CV

5171627

THIRD COURT OF APPEALS

AUSTIN, TEXAS

5/6/2015 11:21:26 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 5/6/2015 11:21:26 AM JEFFREY D. KYLE Clerk
Appellant’s First Motion for Extension of Time to File Brief Page 2 of 5

Identity of Parties and Counsel

Appellant/Petitioner: Petitioner/Appellant’s Appellate Counsel:

Tedde R. Blunck, Pro Se

502 Quitman Street

P O Box 1152

Pittsburg, Texas 75686

Telephone: (903) 855-8460

Telecopier: (903) 855-8465

E-mail: tblunck@yahoo.com

Appellee/Respondent: Respondent/Appellee’s Appellate Counsel:

Mr. Karl E. Hays

State Bar No. 09307050

Law Office of Karl E. Hays, PLLC

2101 South Highway 35, Suite 210

Austin, Texas 78741

Telephone: (512) 476-1911

Telecopier: (512) 476-1904

E-mail: Service@haysfamilylaw.com
Appellant’s First Motion for Extension of Time to File Brief Page 3 of 5

TO THE HONORABLE THIRD COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant Tedde R. Blunck, files 

this First Motion to Extend Time to File Appellant’s Brief. It is presumed that the 

extension is opposed as counsel for Appellee has not responded to Appellant’s request.

Appellant’s opening brief is currently due on May 8, 2015.

Appellant requests a 31-day extension of time to file its brief, making the brief due 

on June 8, 2015. This is the first request for extension of time to file the opening brief.

Appellant relies on the following reasons, in addition to the routine matters that 

Appellant as a practicing attorney must attend to in daily practice, to explain the need for 

the requested extension:

Appellant has been spending a great deal of time with urgent matters 

caused by the untimely death of a client’s father.

Appellant, as a solo practicing attorney, has primary responsibility in the 

following lawsuits which involve complex issues and significant time in 

research: Complicated partition proceedings involving the sale of rural real 

estate complicated by language in a Will being probated and Guardianship 

proceedings for benefit of a minor named in the Will as the beneficiary of 

the Will with respect to the land being partitioned and sold.

Appellant recently lost his ability to perform legal research on line during 

the period from when the Court Reporter’s Record was filed and when the 

Brief is due. There was a substantial period of time when Appellant was 

unable to perform legal research on line and there are no law libraries 

within a reasonable distance to allow the research necessary to prepare the 

brief. The service has now been restored.

Appellant 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. This request is not sought 

for delay but so that justice may be done.
Appellant’s First Motion for Extension of Time to File Brief Page 4 of 5

The undersigned has attempted to confer with opposing counsel, and he has not 

responded. It is therefore presumed that he does oppose this motion. 

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

signing this motion, therefore, no verification is necessary under Rule of Appellate 

Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellant requests that this Court grant this First 

Motion to Extend Time to File Appellant’s Brief and extend the Deadline for Filing the 

Appellant’s Brief up to and including June 8, 2015. Appellant requests all other relief to 

which it may be entitled.

Respectfully submitted,

____________________________________

Tedde R. Blunck

502 Quitman Street

P O Box 1152

Pittsburg, Texas 75686

Telephone: (903) 855-8460

Telecopier: (903) 855-8465

E-mail: tblunck@yahoo.com

Pro Se
Appellant’s First Motion for Extension of Time to File Brief Page 5 of 5

CERTIFICATE OF CONFERENCE

Pursuant to Tex. R. App. P. 10.1(5), I certify that I conferred with counsel for 

Appellee regarding this motion and that Appellee is opposed to this motion.

Tedde R. Blunck

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. P. 9.5, I certify that on May 6, 2015 I served a copy of 

this motion by e-service to the following counsel:

Mr. Karl E. Hays

State Bar No. 09307050

Law Office of Karl E. Hays, PLLC

2101 South Highway 35, Suite 210

Austin, Texas 78741

Telephone: (512) 476-1911

Telecopier: (512) 476-1904

E-mail: service@haysfamilylaw.com

Counsel for Appellee

Tedde R. Blunck