ACCEPTED
05-14-00967-cv
FIFTH COURT OF APPEALS
DALLAS, TEXAS
2/24/2015 1:01:22 PM
LISA MATZ
CLERK
CASE NO. 05-14-00967-CV
IN THE FIFTH DISTRICT COURT OF APPEALS FILED IN
DALLAS, TEXAS 5th COURT OF APPEALS
DALLAS, TEXAS
2/24/2015 1:01:22 PM
LISA MATZ
SHORE CHAN DEPUMPO LLP AND EDWARD MANDEL Clerk
v.
STEVEN W. THRASHER D/B/A THRASHER ASSOCIATES L.L.C.
On Appeal from the 193rd Judicial District Court
Dallas County, Texas
Trial Court Cause No. DC-13-10549
AGREED MOTION FOR EXTENSION OF TIME TO FILE
APPELLANTS’ REPLY BRIEF
Respectfully submitted,
Michael W. Shore
Texas Bar No. 18294915
Russell J. DePalma
Texas Bar No. 00795318
SHORE CHAN DEPUMPO LLP
Bank of America Plaza
901 Main Street, Suite 3300
Dallas, Texas 75202
214-593-9110 Telephone
214-593-9111 Facsimile
Attorneys for all Appellants
TO THE HONORABLE FIFTH COURT OF APPEALS:
Shore Chan DePumpo LLP and Edward Mandel (collectively the
“Appellants”), hereby move this Court to extend the time to file their reply brief by
7 days. Appellants have conferred with counsel for the Appellees and Appellees
have agreed to this motion for an extension. In further support of this motion, the
Appellants assert the following:
1. Current Deadline March 2, 2015. The reply brief for the Appellants is
due on March 2, 2015.
2. Length of Extension: 7 days. The Appellants respectfully request an
extension of the current deadline be enlarged by 7 days to file their brief
so that the new due date would be March 9, 2015.
3. Basis for Extension: The Appellants request additional time for briefing
due to the schedules of their counsel. The extension is not sought for
delay but to ensure justice can be done.
4. Agreed Upon Motion: As noted above, counsel for Appellees has
agreed to the Appellants’ request for a 7-day extension. It would not be
prejudicial for this court to grant the motion.
WHEREFORE, for the foregoing reasons, the Appellants respectfully pray
that this Court grant their motion for an extension of time to file their brief so that
the new deadline will be March 9, 2015. The Appellants pray for any other relief
to which they may be entitled.
Respectfully submitted,
/s/ Michael W. Shore
Michael W. Shore
Texas Bar No. 18294915
Russell J. DePalma
Texas Bar No. 00795318
SHORE CHAN DEPUMPO LLP
Bank of America Plaza
901 Main Street, Suite 3300
Dallas, Texas 75202
214-593-9110 Telephone
214-593-9111 Facsimile
Attorneys for all Appellants
CERTIFICATE OF CONFERENCE
On February 20, 2015, the undersigned counsel conferred with counsel for
Appellees, Steven Ramos, to request whether counsel would agree to a 7-day
extension. Counsel for the Appellees agreed.
_/s/Russell DePalma
Russell DePalma
CERTIFICATE OF SERVICE
The undersigned hereby certifies that the within document has been served
via facsimile on this 24th day of February, 2015.
W. Randall Ackerman
Steven Ramos
Ackerman & Savage, L.L.C.
8226 Douglas Avenue, Suite 330
Dallas, TX 75225
/s/Russell J. DePalma
Russell J. DePalma