ACCEPTED 08-21-00135-CV EIGHTH COURT OF APPEALS EL PASO, TEXAS 08-21-00135-CV 10/28/2021 1:03 PM ELIZABETH G. FLORES CLERK IN THE COURT OF APPEALS FOR THE EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS FILED IN 8th COURT OF APPEALS EL PASO, TEXAS OSVALDO RODRIGUEZ BORUNDA § 10/28/2021 1:03:50 PM AND EDITORA PASO DEL NORTE, § ELIZABETH G. FLORES S.A. DE C.V., § Clerk § Appellants, § § v. § No. 08-21-00135-CV § FREE AND SOVEREIGN STATE OF § CHIHUAHUA, § § Appellee. §

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

TO THE HONORABLE COURT OF APPEALS: COMES NOW Osvaldo Rodriguez Borunda and Editora Paso Del Norte, S.A. de C.V., Appellants, and files this, their First Unopposed Motion for an Extension of Time to File Appellants’ Reply Brief, and in support thereof, would respectfully show as follows: 1. Appellants filed their Brief on September 2, 2021.

2. Appellee’s Response Brief was due on September 30, 2021. Appellee was granted an extension until October 13, 2021 to file his Brief.

3. Appellee filed his Response Brief on October 14, 2021.

{1130.153/HDAV/06856112.1} 4. Appellants’ Reply Brief is due to be filed November 3, 2021.

5. Appellants request an extension of time to November 15, 2021 to file their Reply Brief.

6. This extension is requested because Appellants’ attorney will be unable to complete the Reply Brief by the due date because of counsel’s responsibilities on other urgent client matters.

7. This is Appellants’ first motion for an extension of time to file Appellants’ Reply Brief. This request is not made for purposes of delay, but so that justice may be done. Appellee has consented to this request.

8. For these reasons, Appellants, requests an extension of time to November 15, 2021 to file Appellants’ Reply Brief, and such other and further relief to which they may be justly entitled.

Respectfully submitted, GORDON DAVIS JOHNSON & SHANE P.C.

4695 N. Mesa Street El Paso, Texas 79912 (915) 545-1133 (915) 545-4433 (Fax) [email protected]

By: /s/ Harrel L. Davis Harrel L. Davis III State Bar No. 05567560 Attorney for Appellants

{1130.153/HDAV/06856112.1} CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was filed with the Court via the EFile.TXCourts.gov system on October 28, 2021. All attorneys identified with the Court for electronic service on record in this case were served by electronic service in accordance with the EFile.TXCourts.gov system.

/s/ Harrel L. Davis Harrel L. Davis III

CERTIFICATE OF CONFERENCE The undersigned attorney has conferred with counsel for Appellee who stated he does not oppose this motion.

/s/ Harrel L. Davis Harrel L. Davis III

{1130.153/HDAV/06856112.1} Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Virginia Rust on behalf of Harrel Davis III Bar No. 5567560 [email protected] Envelope ID: 58633589 Status as of 10/28/2021 2:34 PM MST Associated Case Party: Editora Paso Del Norte, S.A. de C.V. Name BarNumber Email TimestampSubmitted Status Harrel LDavis III [email protected] 10/28/2021 1:03:50 PM SENT Virginia Rust [email protected] 10/28/2021 1:03:50 PM SENT Cynthia Canales [email protected] 10/28/2021 1:03:50 PM SENT Victoria Pena [email protected] 10/28/2021 1:03:50 PM SENT

Associated Case Party: Free and Sovereign State of Chihuahua Name BarNumber Email TimestampSubmitted Status Jessica Salto [email protected] 10/28/2021 1:03:50 PM SENT Caroline Adams [email protected] 10/28/2021 1:03:50 PM SENT Christopher Leavitt [email protected] 10/28/2021 1:03:50 PM SENT Anthony Buzbee [email protected] 10/28/2021 1:03:50 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status R. Yetter [email protected] 10/28/2021 1:03:50 PM SENT Matthew Zorn [email protected] 10/28/2021 1:03:50 PM SENT Lisa Prince [email protected] 10/28/2021 1:03:50 PM SENT Bryce Callahan [email protected] 10/28/2021 1:03:50 PM SENT Victor Firth [email protected] 10/28/2021 1:03:50 PM SENT