ACCEPTED
05-14-00874-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
5/18/2015 10:26:54 AM
LISA MATZ
CLERK
NO. 05-14-00874-CV
FILED IN
IN THE COURT OF APPEALS 5th COURT OF APPEALS
DALLAS, TEXAS
5/18/2015 10:26:54 AM
FOR THE FIFTH DISTRICT OF TEXAS
LISA MATZ
Clerk
AT DALLAS
HASSAN PARSA,
Appellant,
v.
VINCENT WALKER,
Appellee.
On Appeal from Cause No. DC-13-11870
14th Judicial District Court, Dallas Couty, Texas
Hon. Eric Moyé, Judge Presiding
SECOND MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLANT
TO THE HONORABLE COURT OF APPEALS:
COMES NOW, Appellant Hassan Parsa, respectfully moves this Honorable Court
for a second extension of time in which to file his brief, stating as follows:
1. The court below is the 14th District Court, Dallas County, Texas.
2. This is an appeal from an order dated June 9, 2014.
3. A notice of appeal was timely filed on July 3, 2014. The Clerk’s Record
was filed on August 5, 2014. The Reporter’s Record was filed July 25, 2014.
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 1
4. By order dated August 25, 2014, this appeal was abated due to the
bankruptcy of Appellant. By order dated March 18, 2015, the stay was lifted by this
Court and Appellant’s brief was due to be filed April 15, 2015.
5. By Order dated April 15, 2015, pursuant to extension, Appellant’s Brief is
currently due to be filed with this Court on May 17, 2015.
6. It is impossible to adequately prepare the brief of Appellant in the current
time allowed. Although counsel for Appellant was counsel in the trial court, the delay
caused by the bankruptcy has caused the record to go cold, and it must be thoroughly re-
reviewed. Further, counsel’s spouse had surgery on March 30, 2015, leaving her
incapacitated for a period of two months. During this period counsel has also had to
prepare and file a Reply to Response to Petition for Review in the Supreme Court (filed
April 30, 2015) in Goodwin v. QuikTrip Corp., No. 14-1076. Counsel for Appellant
requests additional time to adequately prepare the brief of Appellant in the current time
allotted.
7. The extension sought in this motion is not sought solely for purposes of
delay, but only so that justice may be done.
8. Counsel for Appellee was asked if he opposed this motion on Thursday,
May 14, 2015. As of Monday, May 18, 2015, no response has been received.
9. An extension of thirty (30) days is sought by this motion.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests
that the time in which he may file his Brief be extended to and including June 15, 2015,
and for such other and further relief to which he may be entitled at law or in equity.
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 2
Respectfully submitted,
/s/ Mark Donheiser
RANDAL MATHIS
State Bar No. 13194300
MARK DONHEISER
State Bar No. 05974800
MATHIS & DONHEISER
1412 Main Street, Suite 2600
Dallas, TX 75202
Telephone: 214.303.1919
Facsimile: 214.303.0399
ATTORNEYS FOR HASSAN PARSA
CERTIFICATE OF CONFERENCE
Counsel for Appellee, Jerrod David, has not responded to a May 14, 2015 request
for conference on this motion
Signed this 18th day of May, 2015.
/s/ Mark Donheiser
MARK DONHEISER
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document has
been forwarded to all other known counsel of record as listed below, via facsimile, in
accordance with the Texas Rules of Civil Procedure on this 18th day of May, 2015.
Mr. Jerrod L. Davis
Brady & Brady, PLLC
6440 N. Central Expressway, Suite 610
Dallas, Texas 75206
/s/ Mark Donheiser
MARK DONHEISER
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 4