Barbara Meredith v. Oxford Townhomes, LLC Jason Rose Individually, JR Rose Development, LLC Oxford Townhomes Addition Homeowner Association Incorporated David Nolan, Jr Homeowner's Management Enterprises, Inc. D/B/A Home of Texas Warranty Underwriters

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ACCEPTED 05-15-00054-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 6/26/2015 11:45:50 AM LISA MATZ CLERK No. 05-15-00054-CV FILED IN 5th COURT OF APPEALS COURT OF APPEALS FOR THE FIFTH J UDICIALDALLAS, TEXAS 6/26/2015 11:45:50 AM DISTRICT OF TEXAS LISA MATZ Clerk AT DALLAS, TEXAS BARBARA MEREDITH Appellant v. OXFORD TOWNHOMES ADDITION HOMEOWNERS’ ASSOCIATION, INC. Cross Appellant v. OXFORD TOWNHOES, LLC; JASON ROSE; JR ROSE DEVELOPMENT, LLC, OXFORD TOWNHOMES ADDITION HOEOWNER’S ASSOCIATION; HOME OWNERS MANAGEMENT ENTERPRISES, INC. D/B/A HOME OF TEXAS; and WARRANTY UNDERWRITERS INSURANCE COMPANY APPELLANT’S THIRD UNOPPOSED MOTION FOR EXTENSION OF 3 DAYS TO FILE APPELLANT’S BRIEF TO THE HONORABLE COURT OF APPEALS: NOW COMES, BARBARA MEREDITH, (“Appellant”) and files Appellant’s Third Unopposed Motion For Extension Of Time To File Appellant’s Brief and in support would show the Court as follows: I. CERTIFICATE OF CONFERENCE I hereby certify Appellant’s counsel, JANET RANDLE, has conferred with counsel for each of the Appellees and Cross-Appellant and that each counsel is unopposed to this motion. /s/ JANET R. RANDLE ______________________ II. STATEMENT OF FACTS 1. Appellant’s brief and Cross-Appellant’s brief was to be filed Friday, June 26, 2015 the day this motion is being filed. 2. Appellant seeks a three-day extension until Monday June 29, 2015. 3. This request is being made due to counsel’s current litigation calendar which has three other deadlines on motions to dismiss in federal court also due today. 2 APPELLANT’S THIRD UNOPPOSED MOTION FOR EXTENSION OF 3 DAYS TO FILE APPELLANT’S BRIEF MORP Mtn4 Extension Brief to June 29 2015 4. The briefing on those responses has interfered with the ability of counsel to set aside full blocks of time to complete the Appellant’s Brief in this case. 5. Appellant’s counsel intends to utilize the weekend to have the brief completed to file on Monday by the midnight deadline. 6. This motion is made in the interest of justice, and is not intended to intentionally cause delay or to harass opposing counsel. III. AUTHORITY FOR EXTENSION 7. The Court may grant an extension of time under the authority of Texas Rules of Appellate Procedure 38.6(d). IV. PRAYER FOR RELIEF WHEREFORE PREMISES CONSIDERED, Appellee respectfully requests that this Court grant Appellant LEN MAC DEVELOPMENT CORPORATION’S motion for an extension of 3 days to allow it’s counsel to file its opening brief by midnight on June 29, 2015, Respectfully submitted, /s/ JANET R. RANDLE EVAN LANE (VAN) SHAW Bar Card No. 18140500 JANET R. RANDLE Bar Card No. 00792216 2723 Fairmount Street Dallas, Texas 75201 Tel: (214) 754-7110 janet@shawlaw.net 3 APPELLANT’S THIRD UNOPPOSED MOTION FOR EXTENSION OF 3 DAYS TO FILE APPELLANT’S BRIEF MORP Mtn4 Extension Brief to June 29 2015 Fax: (214) 754-7115 ATTORNEYS FOR APPELLANT LEN- MAC DEVELOPMENT CORP. CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document has been forwarded to all counsel via Efile and at the emails noted below: Mr. Jerry L. Ewing, Jr. Mr. Nathan R. Cash Walters Balido & Crain mailto:nathan.cash@wbclawfirm.com Attorneys for Defendants OXFORD TOWNHOMES ADDITION HOMEOWNER ASSOCIATION, INCORPORATED and DAVID NOLAN, JR. Mr. Scott Campbell ATTORNEY AT LAW scampbell@scampbellaw.com Attorney for Defendant OXFORD TOWNHOMES ADDITION HOMEOWNER ASSOCIATION, INCORPORATED Mr. Daniel Bates Mr. Matt Motes ATTORNEY AT LAW dbates@deckerjones.com mmotes@deckerjones.com Notice of Appearance for Defendants JASON ROSE AND JR ROSE DEVELOPMENT, LLC Mr. Mark Davis Mr. Eric L. Lindstrom ATTORNEY AT LAW MDavis@cdklawfirm.com ELindstrom@cdklawfirm.com 4 APPELLANT’S THIRD UNOPPOSED MOTION FOR EXTENSION OF 3 DAYS TO FILE APPELLANT’S BRIEF MORP Mtn4 Extension Brief to June 29 2015 Attorney for Defendants HOME OWNERS MANAGEMENT ENTERPRISES, INC. D/B/A HOME OF TEXAS and WARRANTY UNDERWRITERS INSURANCE COMPANY DATED: June 26, 2015. /s/ JANET R. RANDLE __________________________ JANET R. RANDLE 5 APPELLANT’S THIRD UNOPPOSED MOTION FOR EXTENSION OF 3 DAYS TO FILE APPELLANT’S BRIEF MORP Mtn4 Extension Brief to June 29 2015