### 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 22 ND DISTRICT COURT, HAYS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 11 -1217

APPEL L ANT’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

CLERKAppellant’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

S tate B ar 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.comAppellant’s First Motion for Extension of Time to File Brief Page 3 of 5

TO THE HONORABLE THIRD COURT OF APPEALS:

Pursuant to T EX . R. A PP . 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 M ay 8 , 201 5

.

Appellant requests a 3 1

- day extension of time to file its brief, making the brief due

on J une 8 , 201 5

. 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 ne ed for

the requested extension :

Appellant has been s pending 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: C omplicated p artition proceedings involving the sale of rural real estate complicated by language in a Will being probated and Guardianship proceedings for benefit of a minor n amed in the Will as the beneficiary of

the W ill with respect to the land being partitioned and sold

.

A ppellant recently lost his ability to perform legal research on line during the period from when the Court Reporter ’ s R ecord 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 serv ice has now been restored.

Appellant seeks this extension of time to be able to pre pare 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 w ith 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 t o Extend Time to File Appellant ’s Brief and extend the Deadline f or Filing the

Appellant’s Brief up to and including J une 8 , 201 5 . 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 SeAppellant’s First Motion for Extension of Time to File Brief Page 5 of 5 C ERTIFICA TE OF C ONFERENCE

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

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

Tedde R. Blunck

C ERTIFICATE OF S ERVICE

Pursuant to Tex. R. App. P. 9.5, I certify that on M a y 6 , 201 5 I s erv ed a copy of

this motion by e

- ser vice to the following counsel:

Mr. Karl E. Hays

S tate B ar 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