ACCEPTED 04-15-00536-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 10/20/2015 3:35:20 PM KEITH HOTTLE CLERK

04-15-00536-CV FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS In the Court of Appeals for the Fourth Judicial10/20/2015 District3:35:20 PM at San Antonio, Texas KEITH E. HOTTLE Clerk ________________________ ROMERO LONGORIA, ET AL, Appellants, v. EXXON MOBIL CORPORATOIN, ET AL Appellees, ___________________ FROM THE 79TH DISTRICT COURT OF BROOKS COUNTY, TEXAS, THE HONORABLE RICHARD C. TERRELL, PRESIDING APPELLANTS’ FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF __________________________________________ TO THE HONORABLE JUSTICES OF THE FOURTH COURT OF APPEALS: Appellants Romeo Longoria, et al, files their motion to request that the time for filing their Brief be extended by 30 days to November 23rd (the 21st being a Saturday), 2015, and as reasonable explanation for the extension, shows the following: 1. This appeal was perfected by the filing of a Notice of Appeal. The original record was filed on September 22, 2015, making Appellants’ brief due October 22, 2015.

2. The undersigned attorney is solely responsible for the preparation of Appellants’ Brief.

3. This extension is not sought for purposes of delay. To the contrary, the inability to file Appellants’ Brief by the due date was not deliberate or intentional, but was caused by the following: (1) A delay in getting the clerk’s record, which was not corrected and filed until October 14, 2015 and which Appellants’ counsel has yet to receive; (2) Preparation for oral argument in Cause No. 14-0901; Union Pacific Railroad v. Nami at the Supreme Court of Texas scheduled for November 3, 2015; (3) Preparation for Mediation in Cause No. 13-15-00310-CV ;Service Supply of Victoria, Inc. v. All Seasons HAC; In the Thirteenth Court of Appeals, Scheduled for October 26, 2015.

Certificate of Conference 4. There has been no previous request for extension. Counsel for Appellants did not attempt to reach out to the numerous counsel in this case for a conference, but ask that they let the undersigned or the Court know if they are opposed to this first extension.

WHEREFORE, Appellants request the Court to extend the time for filing their brief to November 23, 2015, and for such other relief to which they may be entitled.

Respectfully submitted,

/s/ Cynthia T. Sheppard CYNTHIA T. SHEPPARD Attorney at Law State Bar No. 20245500 P.O. Box 67 Cuero, Texas 77954 Tele. (361) 277-8539 Fax (361) 277-8571

ATTORNEY FOR APPELLANTS

CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of Appellants’ First Motion for Extension to File Brief was forwarded to all parties to the trial court’s judgment by e-filing service or email on this the 20th day of October, 2015, as follows:

/s/ Cynthia T. Sheppard ________________________________ Cynthia T. Sheppard

Darrell Barger [email protected] J. Reid Simpson [email protected] J. Derrick Price [email protected] Patton Lockridge [email protected] Claude Henkel III [email protected] Robert Luther [email protected] William Wood [email protected] Lauren Varnado [email protected] John Nelson [email protected] Edmundo Ramirez [email protected] Daniel McClure [email protected] Erin Hudson [email protected] Michael Rodriguez [email protected] Rebecca Cole [email protected] Jordan Mullins [email protected] Travis Barton [email protected]