ACCEPTED
03-15-00368-CV
7740700
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/9/2015 11:33:56 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00368-CV
IN THE FILED IN
THIRD COURT OF APPEALS 3rd COURT OF APPEALS
AUSTIN, TEXAS
AUSTIN, TEXAS 11/9/2015 11:33:56 AM
JEFFREY D. KYLE
_______________________________________ Clerk
Laura Pressley,
Appellant,
v.
Gregorio “Greg” Casar,
Appellee.
_______________________________________
No. 03-15-00505-CV
David Rogers,
Appellant,
v.
Gregorio “Greg” Casar,
Appellee.
_______________________________________
UNOPPOSED MOTION TO EXTEND TIME
TO FILE APPELLEE’S BRIEFS
_______________________________________
TO THE HONORABLE THIRD COURT OF APPEALS:
On September 25, 2015, the Court granted Appellee Gregorio “Greg” Casar’s
Unopposed Motion to Consolidate and Reset Briefing Deadlines. Accordingly, the
deadlines in both of the above-styled appeals run from the filings in No. 03-15-00505-
CV. Appellant filed his brief in No. 03-15-505-CV on October 27, 2015, making
Appellee’s briefs for both appeals due on November 16, 2015. Pursuant to Rule
10.5(b) and Rule 38.6 of the Texas Rules of Appellate Procedure, Appellee files this
unopposed motion and asks for a thirty (30) day extension of time by which to file his
briefs. Granting this motion would make the briefs due on December 16, 2015.
Appellee seeks this extension because his appellate counsel, Kurt Kuhn, has
several other matters that have and continue to consume his docket, including:
• Preparing an amicus brief in No. 14-0743; Southwest Royalties, Inc. v. Hegar;
Supreme Court of Texas;
• Preparing a Reply in Support of Petition for Review in No. 15-0504;
Arbor Windsor Court, Ltd., v. Weekley Homes, L.P.; Supreme Court of
Texas;
• Preparing an amicus brief in No. 15-0523; ACE Cash Express, Inc. v. The
City of Denton, Texas; in the Texas Supreme Court; and
• Preparing a petition for review in No. 15-0725, Debra Hren v. Recruiting
Partners GP, Inc. d/b/a Kinney Recruiting, Inc., due on December 4, 2015.
This request is not made for the purpose of delay. It is necessary to allow
Appellee’s counsel time to properly prepare the briefs. This motion is the first
extension requested in this matter, and counsel for Appellants does not oppose the
relief sought.
Prayer
For these reasons, Appellee asks for an additional thirty (30) days to file his
briefs, extending the time until December 16, 2015.
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Dated: November 9, 2015 Respectfully submitted,
By:/s/Kurt Kuhn
Charles Herring, Jr. Kurt Kuhn
State Bar No. 09534100 State Bar No. 24002433
cherring@herring-irwin.com kurt@kuhnhobbs.com
Lauren Ross Lisa Bowlin Hobbs
State Bar No. 24092001 State Bar No. 24026905
laurenbross@herring-irwin.com lisa@kuhnhobbs.com
HERRING & PANZER, L.L.P. KUHN HOBBS PLLC
1411 West Avenue, Suite 100 3307 Northland Drive, Suite 310
Austin, Texas 78701 Austin, Texas 78731-4946
(512) 320-0665 (512) 476-6000
(512) 519-7580 (fax) (512) 476-6002 (fax)
Jessica Palvino
State Bar No. 24048780
jpalvino@mcginnislaw.com
MCGINNIS, LOCHRIDGE & KILGORE, LLP
600 Congress Avenue, Suite 2100
Austin, Texas 78701
(512) 495-6079
(512) 505-6379 (fax)
Counsel for Appellee
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CERTIFICATE OF CONFERENCE
Pursuant to Texas Rule of Appellate Procedure 10.1, I hereby certify that I
conferred with Appellant David Rogers and counsel for Laura Pressley, Mark Cohen,
regarding this motion. Both Mr. Rogers and Mr. Cohen indicated that they are
unopposed to the extension of time.
/s/ Kurt Kuhn
Kurt Kuhn
CERTIFICATE OF SERVICE
I hereby certify that, November 9, 2015, I served electronically a copy of this
motion on counsel of record as listed below:
Mark Cohen
805 West 10th Street, Suite 100
Austin, Texas 78701
mark@cohenlegalservices.com
David Rogers
Law Office of David Rogers
1201 Spyglass Suite 100
Austin, TX 78746
Firm@DARogerslaw.com
/s/ Kurt Kuhn
Kurt Kuhn
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