ACCEPTED 04-14-00758-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 8/4/2015 6:27:23 PM KEITH HOTTLE CLERK NO. 04-14-00758-CV FILED IN 4th COURT OF APPEALS IN THE COURT OF APPEALS SAN ANTONIO, TEXAS FOURTH COURT OF APPEALS DISTRICT OF TEXAS 08/04/15 6:27:23 PM SAN ANTONIO, TEXAS KEITH E. HOTTLE Clerk

JOHN A. LANCE, DEBRA L. LANCE, F.D. FRANKS AND HELEN FRANKS APPELLANTS V. JUDITH AND TERRY ROBINSON, GARY AND BRENDA FEST, VIRGINIA GRAY, BUTCH TOWNSEND AND BEXAR-MEDINA-ATASCOSA COUNTIES WATER CONTROL AND IMPROVEMENT DISTRICT NO. 1 APPELLEES

APPELLANTS’ UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF

TO THE HONORABLE JUSTICES OF THE COURT: JOHN A LANCE, DEBRA L. LANCE, F.D. FRANKS and HELEN FRANKS, Appellants, submit their First Unopposed Motion for Extension of Time to File Appellants’ Reply Brief and in support of this motion state as follows: 1. Appellees, JUDITH AND TERRY ROBINSON, GARY AND BRENDA FEST, VIRGINIA GRAY, BUTCH TOWNSEND and BEXAR- MEDINA-ATASCOSA COUNTIES WATER CONTROL AND IMPROVEMENT DISTRICT NO. 1, filed their Amended Brief on July 16, 2015.

Appellants’ Reply Brief is due August 5, 2015.

2. This motion is filed prior to the expiration of this due date.

3. The undersigned has conferred with the attorneys for Appellees and this motion is unopposed.

4. Appellants request an additional twenty-three (23) days to file their Appellants’ Reply Brief, extending the time to August 28, 2015.

5. No extension has previously been granted.

6. The undersigned is responsible for the preparation of this Appellants’ Reply Brief. The undersigned has been engaged in the preparation of the Brief on the Merits in Gonzales v. Sloan, No. 14-1015, pending in the Supreme Court of Texas. The undersigned has further been engaged in providing litigation support in numerous trial courts and in conducting numerous mediations.

7. This extension request is not filed for purposes of delay.

PRAYER Appellants ask this Court to grant their motion extending the deadline to file their Appellants’ Reply Brief to August 28, 2015.

Respectfully submitted, Cynthia Cox Payne Texas Bar No. 24001935 P.O. Box 1178 1118 Main Street Bandera, TX 78003 (830) 796-7030 – Phone (830) 796-7945 – Fax [email protected] John D. Payne Texas Bar No. 15658500 P.O. Box 1178 1118 Main Street Bandera, TX 78003 (830) 796-7030 – Phone (830) 796-7945 – Fax [email protected] LAW OFFICE OF DAN POZZA E. Commerce Street San Antonio, TX 78205 (210) 226-8888 – Phone (210) 224-6373 – Fax [email protected]

/s/Dan Pozza State Bar No. 16224800 ATTORNEYS FOR APPELLANTS

CERTIFICATE OF SERVICE I hereby that a true and correct copy of the above and foregoing document has been delivered via e-mail transmission on this 5th day of August, 2015, to: Stephan B. Rogers Ross S. Elliott Rogers & Moore Water Street, Suite 114 Boerne, Texas 78006 Attorney for Plaintiffs [email protected] Attorneys for Judith and Terry Robinson, Gary and Brenda Fest, Virginia Gray and Butch Townsend Edward Hecker GOSTOMSKI & HECKER Urban Loop San Antonio, Texas 78204 [email protected] Attorney for Bexar-Medina-Atascosa Counties Water Control and Improvement District No. 1

/s/Dan Pozza