ACCEPTED
14-15-00123-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/20/2015 2:07:36 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS
FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS
AT HOUSTON FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
7/20/2015 2:07:36 PM
No. 14-15-00123-CV CHRISTOPHER A. PRINE
Clerk
Kelvin Gold,
Appellant
v.
Helix Energy Solutions Group, Inc. and Helix Offshore International, Inc.
Appellees
On Appeal from the 270th District Court, Harris County, Texas
Trial Court Cause No. 2013-59134
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
Caj D. Boatright
State Bar No. 24036237
cboatright@arnolditkin.com
Kurt B. Arnold
State Bar No. 24036150
karnold@arnolditkin.com
ARNOLD & ITKIN LLP
6009 Memorial Drive
Houston, TX 77007
Telephone: (713) 222-3800
Facsimile: (713) 222-3850
e-service@arnolditkin.com
COUNSEL FOR APPELLANT
TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
Appellant Kelvin Gold (“Gold”), through undersigned counsel, respectfully
moves this honorable Court for an extension of time in which to file Appellant’s
brief in the above-captioned appeal, and as grounds states as follows:
1. The Clerk’s Record on Appeal in this cause was filed on March 23,
2015 with the 14th Court of Appeals.
2. For the last few weeks, Counsel for Gold has been required to travel
out-of-state on numerous occasions for hearings and depositions and will be
traveling to Chicago, Illinois on the day the Gold’s brief is due. Due to counsel for
Gold’s current workload, previously scheduled depositions, court appearances and
trials in other matters, counsel for Gold needs more time to adequately review the
record on appeal and prepare Appellant’s brief.
3. Appellant’s brief is currently due July 21, 2015.
4. Appellant requests an extension of two (2) weeks, so that Appellant’s
brief may be prepared. Such an extension would extend the filing date for
Appellant’s brief to August 4, 2015.
5. This is Gold’s first request for an extension of time on his reply brief.
6. The undersigned has conferred with counsel for Appellee, who has no
opposition to the relief requested, and was granted an extension of time to file its
opening brief.
7. This extension request is not intended for any undue delay or
prejudice, but so that Gold has sufficient time to prepare his brief and that justice
may be done.
WHEREFORE, Gold respectfully requests that this Honorable Court grant
this motion, affording him a two (2) week extension of time, through and until
August 4, 2015, to file his brief, and for such other and further relief as this
Honorable Courts deems appropriate.
Respectfully submitted,
ARNOLD & ITKIN LLP
/s/ Caj D. Boatright
Caj D. Boatright
State Bar No. 24036237
cboatright@arnolditkin.com
Kurt B. Arnold
State Bar No. 24036150
karnold@arnolditkin.com
6009 Memorial Drive
Houston, TX 77007
Telephone: (713) 222-3800
Facsimile: (713) 222-3850
e-service@arnolditkin.com
COUNSEL FOR APPELLANT
CERTIFICATE OF CONFERENCE
Counsel for Appellant Kelvin Gold has conferred with counsel for Appellee
in a good faith effort to avoid any issues that might be raised by this motion.
Counsel for Appellee has advised that he has no opposition to the extension of time
requested herein.
/s/ Caj D. Boatright
Caj D. Boatright
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing
Unopposed Motion for Extension of Time to File Appellant’s Brief has been
forwarded to all counsel of record in accordance with the Texas Rules of Appellate
Procedure on this 20th day of July, 2015.
Susan Noe Wilson
Bland & Partners, PLLC
1717 St. James Place, Suite 360
Houston, Texas 77056
Counsel for Appellees Helix Energy Solutions Group, Inc. and
Helix Offshore International, Inc.
/s/ Caj D. Boatright
Caj D. Boatright