Johannes B. Massar v. Pegasus Pain Management, PLLC

Opinion

ACCEPTED 15-25-00054-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS NO. 15-25-00054-CV 7/24/2025 11:45 AM ______________________________________________________________________________ CHRISTOPHER A. PRINE CLERK IN THE FIFTEENTH COURT OF APPEALS FILED IN AUSTIN, TEXAS 15th COURT OF APPEALS AUSTIN, TEXAS ______________________________________________________________________________ 7/24/2025 11:45:11 AM CHRISTOPHER A. PRINE Clerk JOHANNES B. MASSAR, Appellant v.

PEGASUS PAIN MANAGEMENT, PLLC, Appellee ______________________________________________________________________________

On Appeal from County Court at Law No. 2 Dallas County, Texas ______________________________________________________________________________

APPELLANT’S UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF ______________________________________________________________________________

To the Honorable Justices of the First Court of Appeals:

To the Honorable Court of Appeals:

Appellant requests that the Court extend time for filing of his brief pursuant

to Rules of Appellate Procedure 10.5(b), 38.6(d) and all other applicable rules, and

in support of this motion show:

1. The due date for the Appellant’s Brief’s is August 6, 2025.

2. Appellant’s hereby request to have the due date of their brief extended

for a period of thirty (30) days to September 5, 2025. 3. Appellant’s counsel’s has a scheduled vacation and additional time

constraints with preexisting deadlines have not provided counsel the time needed

to prepare Appellant’s brief fully and fulsomely. This request is not for the purpose

of delay, but so that justice may be done.

4. There have been no previous extensions requested by or granted to

Appellant.

For these reasons, Appellant requests that the Court:

(A) extend the time to file Appellant’s brief to September 5, 2025; and

(B) grant Appellant’s such other and further relief to which she may be

entitled or is in the interest of justice.

Respectfully submitted,

FERNANDEZ L.L.P.

By: /s/Raymond R. Fernandez, Jr. Raymond R. Fernandez, Jr. State Bar No. 06934275 2515 McKinney Avenue, Suite 920 Dallas, Texas 75201 rfernandez@fernandezllp.com Robert L. Knebel, Jr. State Bar No. 11589500 rknebel@fernandezllp.com (214) 231-2700

ATTORNEYS FOR APPELLANT

Appellant’s Motion to Extend Time – Page 2 CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have conferred with Mark Ticer about the merits of this motion and Appellee does not oppose this motion.

Date: July 24, 2025

/s/Robert L. Knebel, Jr. Robert L. Knebel, Jr.

CERTIFICATE OF SERVICE

As required by the Texas Rules of Appellate Procedure, I certify on July 24, 2025, I have served this document electronically through the electronic filing manager to all counsel of record.

/s/Raymond R. Fernandez, Jr. Raymond R. Fernandez, Jr.

Appellant’s Motion to Extend Time – Page 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Raymond Fernandez, Jr. on behalf of Raymond Fernandez, Jr. Bar No. 06934275 rfernandez@fernandezllp.com Envelope ID: 103540034 Filing Code Description: Motion Filing Description: Motion ($10.00) Status as of 7/24/2025 12:05 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Mark Ticer 20018900 mticer@ticerlaw.com 7/24/2025 11:45:11 AM SENT

Robert L.Knebel rknebel@fernandezllp.com 7/24/2025 11:45:11 AM SENT

Raymond R.Fernandez rfernandez@fernandezllp.com 7/24/2025 11:45:11 AM SENT