NO. 04-14-00609 

_____________________________________________________________________________ 

IN THE TEXAS COURT OF APPEALS - FOURTEENTH JUDICIAL DISTRICT 

IRMA LEMUS and MANUEL LEMUS, JR., Appellants 

V. 

JOHNNY MONTOYA GARZA, JOHN RENE AGUILAR, 

LAURA ASHLEY WELLS and JOHNNY B. WELLS, Appellees 

On Appeal from Cause No. 2012-CI-00251, 225th Judicial District Court of Bexar County 

______________________________________________________________________________ 

APPELLEE'S MOTION FOR EXTENSION 

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: 

COME NOW Appellees, JOHNNY MONTOYA GARZA, JOHN RENE AGUILAR, 

LAURA ASHLEY WELLS and JOHNNY B. WELLS, and respectfully request that this 

Honorable Court grant an additional five days to file their brief on appeal. In support thereof, 

they would show the following: 

I. Jurisdiction 

 This court has jurisdiction to grant an extension of time pursuant to Tex. R. Civ. App. Rule 

38.6(d). 

 Appellees’ brief is due June 12th. Appellants’ redrawn brief was filed on May 11, 2015 as 

ordered by the Court after an initial brief was filed April 20, 2015 upon a thirty day extension. 

 Appellees’ counsel requests such additional time as necessary to complete a competently 

prepared brief fully in compliance with the Texas Rules of Appellate Procedure and, being 

technologically challenged, to assemble an appendix in pdf format, with appropriate references to

the same. 

ACCEPTED

04-14-00609-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

6/12/2015 6:00:23 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 06/12/2015 6:00:23 PM KEITH E. HOTTLE Clerk
Appellees would respectfully show that failure to file on this, the due date, was not 

deliberate or intentional but the result of inadvertence, mistake and mischance. 

WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray for additional 

five days to file their brief on appeal, and for such other and further relief to which they may be 

justly entitled. 

Respectfully submitted, 

/s/ Anita J. Anderson 

ANITA J. ANDERSON 

Texas Bar No. 01165955 

 LAW OFFICE OF ANITA J. ANDERSON 

Conference: 303 West Sunset Suite 103 

Correspondence: POB 830722 

San Antonio, Texas 78283 

Telephone (210) 533-8726 

Telecopier (210) 633-0989 

 ajanderson1111@gmail.com

CERTIFICATE OF SERVICE 

 A true and correct copy of the above and forgoing has been forwarded by e-service and 

facsimile transmission to Ana Laura Hessbrook, attorney of record for Defendants Irma Lemus 

and Manuel Lemus, Jr. at 4100 N.W. Loop 410, Suite 105, San Antonio, Texas 78229 

hessbrook@sbcglobal.net, (210) 706 -9467 and Sarah Anne Lishman, 310 South St. Mary’s St., 

Suite 845, San Antonio, Texas 78205, sarahanne@jamiegrahamlaw.com (210)308-5669 this 12th

day of June, 2015.

/s/ Anita J. Anderson 

ANITA J. ANDERSON 

 
 

WHEREFORE, PREMISES CONSIDERED, Appellees respectfully pray that this 

Honorable Court order an extension of time to Appellees for filing of their brief to and for such 

further relief to which they may be justly entitled. 

Respectfully submitted, 

/s/ Anita J. Anderson 

ANITA J. ANDERSON 

Texas Bar No. 01165955 

 LAW OFFICE OF ANITA J. ANDERSON 

Conference: 303 West Sunset Suite 103 

Correspondence: POB 830722 

San Antonio, Texas 78283 

Telephone (210) 533-8726 

Telecopier (210) 633-0989 

 ajanderson1111@gmail.com

CERTIFICATE OF SERVICE 

 A true and correct copy of the above and forgoing has been forwarded by e-service and 

facsimile transmission to Ana Laura Hessbrook, attorney of record for Defendants Irma Lemus 

and Manuel Lemus, Jr. at 4100 N.W. Loop 410, Suite 105, San Antonio, Texas 78229 

hessbrook@sbcglobal.net, (210) 706 -9467 and Sarah Anne Lishman, 310 South St. Mary’s St., 

Suite 845, San Antonio, Texas 78205, sarahanne@jamiegrahamlaw.com (210)308-5669 this 12th

day of June, 2015. 

/s/ Anita J. Anderson 

ANITA J. ANDERSON