ACCEPTED
01-15-00375-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/2/2015 1:08:19 PM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 01-15-00375-CV
________________________________________
FILED IN
1st COURT OF APPEALS
IN THE FIRST COURT OF APPEALS IN HOUSTON, TEXASHOUSTON, TEXAS
6/2/2015 1:08:19 PM
________________________________________
CHRISTOPHER A. PRINE
Clerk
LOST CREEK VENTURES, LLC D/B/A HAPPY BULLDOG MANAGEMENT; STEPHAN
EPSTEIN, AND MARILYN ROTH EPSTEIN,
Appellants,
v.
ALAN PILGRIM,
Appellee.
________________________________________
On Appeal from the County Court at Law No. 2 in Travis County, Texas
Transferred from the Third Court of Appeals in Austin, Texas
________________________________________
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANTS’ BRIEF
________________________________________
Tracy J. Willi
Willi Law Firm, P.C.
9600 Escarpment Blvd., Suite 745, PMB 34
Austin, TX 78749-1983
Tel. (512) 288-3200
Fax (512) 288-3202
twilli@willi.com
ATTORNEY FOR LOST CREEK
VENTURES, LLC D/B/A HAPPY
BULLDOG MANAGEMENT; STEPHAN
EPSTEIN, AND MARILYN ROTH
EPSTEIN
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANTS’ BRIEF
Happy Bulldog Management; Stephan Epstein, and Marilyn Roth Epstein,
Appellants, filed this First Unopposed Motion for Extension of Time to File
Appellants’ Brief and would show this Court as follows.
The trial court in this case entered judgment on November 10, 2014. This is
the first motion for extension of time filed in this appeal. Appellants’ Brief is
currently due on June 1, 2015.
The Appellants have paid for the Clerk’s Record and that record was filed on
April 24, 2015. The Appellants have been struggling to come up with funding to
pay for the Reporter’s Record. On May 27, 2015, Appellants sent a check to the
Court Reporter for the full amount due, $1,639.00. Appellants wish to proceed
with this appeal after the filing of the Reporter’s Record.
Appellants request an extension of time to July 1, 2015 to file the
Appellants’ Brief. Appellants are hopeful that the Reporter’s Record will be
completed and filed in time to allow the record to be reviewed and to permit the
drafting of the brief by the time. This motion is filed not for delay but so that
justice can be done.
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Respectfully submitted,
/s/ Tracy J. Willi
Tracy J. Willi
Texas Bar No. 00784633
Willi Law Firm, P.C.
9600 Escarpment Blvd., Suite 745, PMB 34
Austin, TX 78749-1983
Tel. (512) 288-3200
Fax (512) 288-3202
twilli@willi.com
ATTORNEY FOR LOST CREEK
VENTURES, LLC D/B/A HAPPY
BULLDOG MANAGEMENT; STEPHAN
EPSTEIN, AND MARILYN ROTH
EPSTEIN
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CERTIFICATE OF CONFERENCE
I hereby certify that I conferred with opposing counsel, Jason Snell, and he
is not opposed to this motion.
/s/ Tracy J. Willi
Tracy J. Willi
CERTIFICATE OF FILING AND SERVICE
I hereby certify that this document was filed with Clerk of Court through the
Court’s electronic filing system (“efs”) and served on all counsel of record through
efs or, if counsel is not registered for efs, then by email on June 2, 2015 as follows:
Jason W. Snell
The Snell Law Firm, PLLC
The Littlefield Building
106 E. 6th St., Suite 330
Austin, TX 78701
(512) 477-5291
(512) 477-5294 (fax)
jsnell@snellfirm.com
COUNSEL FOR APPELLEE, ALAN PILGRIM
/s/ Tracy J. Willi
Tracy J. Willi
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