ACCEPTED
03-15-00505-CV
7274208
THIRD COURT OF APPEALS
AUSTIN, TEXAS
10/7/2015 3:03:39 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00505-CV
IN THE COURT OF APPEALS
FILED IN
FOR THE THIRD SUPREME JUDICIAL DISTRICT
3rd COURT OF APPEALS
AT AUSTIN AUSTIN, TEXAS
10/7/2015 3:03:39 PM
JEFFREY D. KYLE
DAVID ROGERS, Clerk
APPELLANT
VS.
GREGORIO “GREG” CASAR,
APPELLEE
MOTION TO EXTEND TIME FOR FILING APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
Now comes David Rogers, Appellant and pursuant to Tex.R.App.P. 10.5, moves
this court to grant an extension of time to file Appellant’s Brief, and respectfully states:
1. The due date for the Appellant’s Brief is currently October 7, 2015. David Rogers
seeks an extension of time to file Appellant’s brief for 14 days from the current stated due
date of October 7, 2015 or until October 21, 2015. The extension is needed because the
record in this case is voluminous making preparing the brief and appendix more time
consuming than Appellant anticipated. In addition, Appellant has had an unusually high
number of short notice client emergencies that have prevented Appellant from devoting
the time necessary to properly prepare the Appellant’s Brief.
2. Therefore, this Motion is in the interest of justice and orderly presentation of the issues
that need to be resolved in this appeal and not for by reason of any procrastination or for
delay.
3. Appellant has conferred with counsel for Casar and counsel for Pressley and neither
opposes this Motion to Extend Time to October 21, 2015.
4. This is the first extension of time David Rogers has presented to this Honorable Court
for filing of the Appellant’s Brief.
PRAYER
For these reasons, David Rogers requests that this court enter an order extending
the time for filing Appellant’s Brief until October 21, 2015.
Respectfully submitted,
/s/ David Rogers
David Rogers
SBN: 24014089
1201 Spyglass Drive, Suite 100
Austin, Texas 78746
(512) 923-1836
(512) 201-4082
firm@dargoerslaw.com
CERTIFICATE OF CONFERENCE
Please be advised that the undersigned has conferred with opposing counsel on
October 7, 2015 regarding this motion, and the counsel for Gregorio “Greg” Casar and
the counsel for Laura Pressley are unopposed to the Court extending the due date for
Appellant’s Brief until October 21, 2015.
/s/ David Rogers
David Rogers
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing has been
swerved by efile and/or facsimile to the following persons on this 7th day of October
2015.
Mark Cohen
SBN: 04508400
805 W. 10th Street, Suite 100
Austin, Texas 78701
(512) 474-4424
(512) 472-5444 fax
mark@cohenlegalservices.com
ATTORNEY FOR APPELLANT
LAURA PRESSLEY
Kurt Kuhn
SBN: 24002433
KUHN HOBBS PLLC
3307 Northland Drive, # 310
Austin, Texas 78731
(512) 476-6000
(512) 476-6002 fax
kurt@KuhnHobbs.com
Charles ‘Chuck’ Herring, Jr.
SBN: 09534100
Herring & Irwin, L.L.P
1411 West Avenue, Suite 100
Austin, Texas 78701
(512) 320-0665
(512) 519-7580 fax
cherring@herring-irwin.com
ATTORNEYS FOR APPELLEE
GREGORIO “GREG” CASAR
/s/ David Rogers
David Rogers