Lost Creek Ventures, LLC D/B/A Happy Bulldog Management Stephan Epstein And Marilyn Roth Epstein v. Alan Pilgrim

Opinion

ACCEPTED

01-15-00375-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS 6/2/2015 1:08:19 PM CHRISTOPHER PRINE

CLERK

CAUSE NO. 01-15-00375-CV

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FILED IN

1st COURT OF APPEALS

IN THE FIRST COURT OF APPEALS IN HOUSTON, TEXASHOUSTON, TEXAS 6/2/2015 1:08:19 PM

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CHRISTOPHER A. PRINE

Clerk

LOST CREEK VENTURES, LLC D/B/A HAPPY BULLDOG MANAGEMENT; STEPHAN EPSTEIN, AND MARILYN ROTH EPSTEIN,

Appellants,

v.

ALAN PILGRIM,

Appellee.

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On Appeal from the County Court at Law No. 2 in Travis County, Texas Transferred from the Third Court of Appeals in Austin, Texas

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FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF

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Tracy J. Willi Willi Law Firm, P.C. 9600 Escarpment Blvd., Suite 745, PMB 34 Austin, TX 78749-1983 Tel. (512) 288-3200 Fax (512) 288-3202 twilli@willi.com

ATTORNEY FOR LOST CREEK VENTURES, LLC D/B/A HAPPY BULLDOG MANAGEMENT; STEPHAN EPSTEIN, AND MARILYN ROTH EPSTEIN

FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF

Happy Bulldog Management; Stephan Epstein, and Marilyn Roth Epstein,

Appellants, filed this First Unopposed Motion for Extension of Time to File

Appellants’ Brief and would show this Court as follows.

The trial court in this case entered judgment on November 10, 2014. This is

the first motion for extension of time filed in this appeal. Appellants’ Brief is

currently due on June 1, 2015.

The Appellants have paid for the Clerk’s Record and that record was filed on

April 24, 2015. The Appellants have been struggling to come up with funding to

pay for the Reporter’s Record. On May 27, 2015, Appellants sent a check to the

Court Reporter for the full amount due, $1,639.00. Appellants wish to proceed

with this appeal after the filing of the Reporter’s Record.

Appellants request an extension of time to July 1, 2015 to file the

Appellants’ Brief. Appellants are hopeful that the Reporter’s Record will be

completed and filed in time to allow the record to be reviewed and to permit the

drafting of the brief by the time. This motion is filed not for delay but so that

justice can be done.

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Respectfully submitted,

/s/ Tracy J. Willi Tracy J. Willi Texas Bar No. 00784633 Willi Law Firm, P.C. 9600 Escarpment Blvd., Suite 745, PMB 34 Austin, TX 78749-1983 Tel. (512) 288-3200 Fax (512) 288-3202 twilli@willi.com

ATTORNEY FOR LOST CREEK VENTURES, LLC D/B/A HAPPY BULLDOG MANAGEMENT; STEPHAN EPSTEIN, AND MARILYN ROTH EPSTEIN

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CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with opposing counsel, Jason Snell, and he is not opposed to this motion.

/s/ Tracy J. Willi Tracy J. Willi

CERTIFICATE OF FILING AND SERVICE

I hereby certify that this document was filed with Clerk of Court through the Court’s electronic filing system (“efs”) and served on all counsel of record through efs or, if counsel is not registered for efs, then by email on June 2, 2015 as follows:

Jason W. Snell The Snell Law Firm, PLLC The Littlefield Building 106 E. 6th St., Suite 330 Austin, TX 78701 (512) 477-5291 (512) 477-5294 (fax) jsnell@snellfirm.com

COUNSEL FOR APPELLEE, ALAN PILGRIM

/s/ Tracy J. Willi Tracy J. Willi