Playa Vista, L.P., Morgan- Multi Family LLC, and Scott Morgan v. Lakeside Re, L.P., GSRE, Inc., and Avi Ron ( 2015 )

ACCEPTED
01-14-00871-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/24/2015 11:25:02 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00871-CV
PLAYA VISTA LP, MORGAN- § FILED IN
1st COURT OF APPEALS
MULTI FAMILY LLC, and SCOTT § HOUSTON, TEXAS
MORGAN § 3/24/2015 11:25:02 AM
Appellant § CHRISTOPHER A. PRINE
§ Clerk
v. §
§ COURT OF APPEALS OF TEXAS
LAKESIDE RE, LP, GSRE, INC., §
and, AVI RON § FIRST DISTRICT
Appellee §
UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLATE BRIEF
Appellants, Playa Vista LP, Morgan-Multi Family LLC, and Scott Morgan,
asks the Court to extend the time to file their Appellate Brief.
Introduction
1. This motion is filed before the Appellate Brief is due. There is no specific
deadline to file this motion to extend time. See Tex. R. App. Proc. 38.6(d).
2. Appellees are unopposed.
Argument & Authorities
3. The Court may grant an extension of time under Texas Rule of Appellate
Procedure 38.6(d) and 10.5(b).
4. The deadline to file the Appellate Brief is March 30, 2015. Appellants request
an additional twenty-one (21) days to file the Appellate Brief, extending the
deadline to Monday, April 20, 2015.
5. Appellants’ counsel had two unforeseen personal emergencies arise over a two
and a half week period.
6. An extension/stay was previously requested due to summary judgment hearings
in the 270th Judicial District Court of Harris County in this cause, causing the
case to be abated. The appeal was reinstated in January. One extension has
been previously granted. This is Appellants’ second request for an extension.
Conclusion and Prayer
7. For the reasons stated above, Appellants ask the Court to grant an extension of
time to file the Appellate Brief until April 20, 2015.
Respectfully Submitted,
PARANJPE & MAHADASS LLP
/s/ Tej Paranjpe___________
Tej R. Paranjpe
State Bar Number: 24071829
3701 Kirby, Suite 530
Houston, Texas 77098
832.667.7700 Telephone
832.202.2018 Facsimile
tparanjpe@pandmllp.com
ATTORNEY FOR APPELLANTS
CERTIFICATE OF CONFERENCE
I certify that I have conferred with opposing counsel, Jerry Hecht, by email,
and he is unopposed to Appellant’s Motion to Extend Time to File Appellate Brief.
/s/ Tej Paranjpe_________
TEJ R PARANJPE
CERTIFICATE OF SERVICE
I hereby certify that, in accordance with Rule 9.5 of the Texas Rules of
Appellate Procedure, I have served the foregoing document upon the following
parties by facsimile or email correspondence:
Jerry Hecht
trialatt@aol.com
Dated: March 24, 2015
/s/ Tej Paranjpe_________
TEJ R PARANJPE