Sahami Investments, Ltd v. Stately Homes, LLC, Theodore More and Bryan Phillips

ACCEPTED
01-14-00999-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/11/2015 4:16:38 PM
CHRISTOPHER PRINE
CLERK

NO. 01-14-00999-CV

IN THE FIRST COURT OF APPEALS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS HOUSTON, TEXAS
3/11/2015 4:16:38 PM
CHRISTOPHER A. PRINE
SAHAMI INVESTMENTS, LTD, Clerk

Appellant

VS.

STATELY HOME, LLC, THEODORE MORE, AND BRYAN PHILLIPS,
Appellees

On Appeal from 113th District Court of Harris County, Texas
Trial Court Cause Number 2014-12172

APPELLANT’S FIRST MOTION FOR EXTENSION OF
TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE FIRST COURT OF APPEALS:

Pursuant to Rule 10.5(b) of the Texas Rules of Appellate Procedure,

Appellant, Sahami Investments, LTD, files this First Motion for Extension of Time

to File Apellant’s Brief and, in support thereof, would respectfully show the Court

as follows:

1. The deadline for Appellant to file the brief was February 25, 2015.

2. Counsel for Appellant is in the process of negotiating a settlement in

this matter and requests additional time to file the Appellant’s Brief.
 3. This request for an extension of time is not sought for delay, but rather

to give counsel for Appellant adequate time to prepare the Brief so that the briefing

will be as helpful as possible to this Court.

4. For the foregoing reasons, Appellant respectfully requests that this

Court grant this First Motion for Extension of Time and give Appellant until May

26, 2015, to file its brief. Appellant respectfully requests any further relief to

which it is justly entitled.

Respectfully submitted,

THE SEILER LAW FIRM, PLLC

_/s/ Kenna M. Seiler__________________
Kenna M. Seiler
State Bar No. 13944250
Erik C. Baumann
State Bar No. 24091292
8505 Technology Forest Place, Suite 1102
The Woodlands, Texas 77381
Telephone: (281) 419-7770
Telecopier: (281) 419-7791
E-mail: kenna.seiler@theseilerlawfirm.com
Erik.baumann@theseilerlawfirm.com

ATTORNEYS FOR APPELLANT
 CERTIFICATE OF CONFERENCE

I hereby certify that I have contacted Stephen Paxson, lead counsel for
Appellees in this matter and he objects to Appellant’s First Motion for Extension
of Time to File Appellant’s Brief.

_/s/ Kenna M. Seiler__________________
Kenna M. Seiler

CERTIFICATE OF SERVICE

Pursuant to Rules 21. and 21a of the Texas Rules of Civil Procedure, I
hereby certify that the original of the Appellant’s First Motion for Extension of
Time to File Appellant’s Brief has been filed with the Clerk of the First Court of
Appeals in writing, and true and correct copies have been delivered to all interested
parties on March 11, 2015, correctly addressed as follows:

Stephen Paxson
Paxson & Associates, P.C.
2240 Bissonnet Street
Houston, TX 77005

Brandon M. Barchus
Faulk Barchus, PLLC
800 Bering Drive, Suite 400
Houston, TX 77057

_/s/ Kenna M. Seiler__________________
Kenna M. Seiler