Opinion
NO. 04-17-00017-CV
05-18-2017
PETRA AGUILERA d/b/a KIDS CONNECTION PRESCHOOL AND YOUTH CENTER DEVELOPMENT CENTER, Appellants, v. YOLANDA IRMA PEREZ, Appellee.
Deborah S. Perry Law Offices of Deborah S. Perry, PLLC 111 Soledad, Suite 300 San Antonio, Texas 78205 Tel: (210) 299-7633 Fax: (210) 299-7753 Email: dspdperry@yahoo.com State Bar No.: 24046617 Counsel for Appellant
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF
Deborah S. Perry
Law Offices of Deborah S. Perry, PLLC
111 Soledad, Suite 300
San Antonio, Texas 78205
Tel: (210) 299-7633
Fax: (210) 299-7753
Email: dspdperry@yahoo.com
State Bar No.: 24046617
Counsel for Appellant
TO THE HONORABLE FOURTH COURT OF APPEALS:
Pursuant to TEX. R. APP. P. 10.1, 10. 5 and 38.6(d), the Appellant, Petra Aguilera, files this First Unopposed Motion for Extension of Time to File Appellant's Brief.
Appellant's opening brief was due on May 5, 2017.
Counsel failed to properly calendar the filing date for the Appellant's opening brief. Also, Counsel erroneously believed that the Court would provide a briefing schedule for this case indicating the original due date for all briefs. It is now understood that the Appellant's opening brief was due within 30 days after the receipt of the Reporter's record providing a due date of May 5, 2017.
Counsel for Appellant requests an extension of time to file its brief, making the brief due on June 9, 2017. This is the first request for an extension of time to file the Appellant's opening brief.
Counsel for Appellant requests this extension so the Counsel can prepare a cogent and succinct brief to aid this Court in its analysis of the issues presented and not punish the Appellant for the misunderstanding of the Appellate Rules exhibited by Counsel.
This Request is not sought for delay but so that justice may be done.
The undersigned has conferred with opposing counsel, and she has indicated that her client does not 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 Rule of Appellate Procedure 10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this unopposed first motion for the Extension of Time to File Appellant's Brief and to extend the Deadline for filing the Appellant's Brief up to and including June 9, 2017. Appellant prays for all other relief to which she may be entitled.
Respectfully submitted,
/s/_________
Deborah S. Perry
Law Offices of Deborah S. Perry, PLLC
111 Soledad, Suite 300
San Antonio, Texas 78205
Tel: (830) 299-7633
Fax: (830) 299-7753
Email: dspdperry@yahoo.com
State Bar No. 24046617
Counsel for Appellant
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing has been served on all parties or their counsel of record in accordance with the Texas Rules of Civil Procedure.
/s/_________
Deborah S. Perry