Christoph Henkel v. Emjo Investments, Ltd. and H.J. Von Der Goltz

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ACCEPTED 01-14-00703-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 2/24/2015 4:26:15 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FIRST APPELLATE DISTRICT FILED IN 1st COURT OF APPEALS NO. 01-14-00703-CV HOUSTON, TEXAS 2/24/2015 4:26:15 PM CHRISTOPHER A. PRINE CHRISTOPH HENKEL Clerk APPELLANT v. EMJO INVESTMENTS, LTD. and H.J. VON DER GOLTZ APPELLEES APPELLEES’ AGREED MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF Appellees Emjo Investments, Ltd. and H.J. von der Goltz file this Agreed Motion for Extension of Time to File Appellees’ Brief under the authority of Texas Rule of Appellate Procedure 10.5(b) and would respectfully show the following: 1. The parties to this appeal are currently engaged in settlement discussions. In the event of a successful settlement, this appeal would be dismissed. Accordingly, Appellees and Appellant Christoph Henkel (“Henkel”) Henkel are in agreement with the request for extension. 2. Appellees seek the 30-day extension of the briefing deadline to allow the parties the opportunity to attempt to resolve the litigation without further expense by the parties and the Court. 3. This is an appeal from an order of the 215th Judicial District Court entered October 21, 2014, denying Henkel’s Special Appearance. 4. Henkel filed his Notice of Appeal on November 10, 2014. Henkel filed his opening brief on January 5, 2015. 5. Appellees’ brief is due to be filed on or before February 25, 2015. 6. This motion seeks an extension of time of 30 days, up to and including March 27, 2015. 7. This is Appellees’ second request for an extension to file their brief. Therefore, Appellees Emjo Investments, Ltd. and H.J. von der Goltz respectfully request that the Court extend the time for them to file their brief by 30 days, up to and including March 27, 2015. Respectfully submitted, ELLISON & KELLER, P.C. /s/Kelley M. Keller By: Kelley M. Keller State Bar No. 11198240 5120 Woodway, Suite 6019 Houston, Texas 77056 Telephone: 713-266-8200 Facsimile: 713-266-8201 kkeller@ellison-keller.com Attorneys for Appellants 2 CERTIFICATE OF CONFERENCE I, Kelley M. Keller, certify that on February 24, 2015, I conferred with counsel for the Appellant regarding settlement discussions in this matter and the briefing schedule in this appeal. Counsel for Appellant is in agreement with the relief sought in this motion. /s/Kelley M, Keller Kelley M. Keller CERTIFICATE OF SERVICE A true and correct copy of this Appellees’ Agreed Motion for Extension of Time to File Appellees’ Brief has been forwarded to all counsel of record on February 24, 2015, via email and/or eservice as follows: Asher Griffin Sean Gorman Chris Sileo Jane Langdell Robinson Sean Flammer Jamie Aycock SCOTT, DOUGLASS & MCCONNICO, LLP AHMAD. ZAVITSANOS, ANAIPAKOS, ALAVI & 600 Congress Ave., Ste 1500 MENSING P.C. Austin, Texas 78701-2589 3460 One Houston Center Facsimile: 512-474-0731 1221 McKinney Street agriffin@scottdoug.com Houston. Texas 77010 Facsimile: 713-658-0062 Attorneys for Defendants sgorman@azalaw.com Chalsys Capital Partners, Meliora Energy jrobinson@azalaw.com Technologies, S.a.r.L, and Sonia Lo jamieaycock@azalaw.com Attorneys for Appellant Christoph Henkel F. Eric Fryar Matthew Buschi Christina Richardson FRYAR LAW FIRM, P.C. 912 Prairie, Suite 100 Houston, Texas 77002-3145 Facsimile: 281-605-1888 eric@fryarlawfirm.com Attorneys for all Intervenors/Plaintiffs /s/Kelley M. Keller Kelley M. Keller 3