ACCEPTED 15-25-00111-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/20/2025 2:52 PM Nos. 15-25-00110-CV; 15-25-00111-CV; 15-25-00112-CV CHRISTOPHER A. PRINE CLERK IN THE FIFTEENTH COURT OF APPEALS FILED IN AUSTIN, TEXAS 15th COURT OF APPEALS AUSTIN, TEXAS 8/20/2025 2:52:56 PM CHRISTOPHER A. PRINE PLEASANTON HOUSING FINANCE CORPORATION, ISMAEL GALLEGOS Clerk , JOEY MACON, MARK PINKSTON, ZACHARY PAWELEK, SCOTT FERGUSON, LILIAN CASHMER, AND BRANDON HICKS, APPELLANTS, V. CITY OF LAKE WORTH, TEXAS, APPELLEE.
PECOS HOUSING FINANCE CORPORATION, PLEASANTON HOUSING FINANCE CORPORATION, MAVERICK HOUSING FINANCE CORPORATION, LA VILLA HOUSING FINANCE CORPORATION, AND JOE DON BOBBITT, APPELLANTS, V. CITY OF ARLINGTON AND CITY OF FORT WORTH, APPELLEES.
PECOS HOUSING FINANCE CORPORATION, CARA TURN, MARIBEL ALVAREZ, AND IRENE DOMINGUEZ, APPELLANTS, V. CITY OF HALTOM CITY, TEXAS, APPELLEE.
UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ OPENING BRIEF
From the 348th District Court, Tarrant County, Texas Cause Nos. 348-364430-25, 348-363561-25, and 348-364135-25; Hon. Megan Fahey, presiding Jeffrey M. Tillotson Blake W. Stribling Texas Bar No. 20039200 Texas Bar No. 24070691 jtillotson@tillotsonlaw.com bstribling@chasnoffstribling.com Kathryn E. Yukevich Daniel J. Decavalier Texas Bar No. 24133390 Texas Bar No. 24129028 kyukevich@tillotsonlaw.com dlecavalier@chasnoffstribling.com TILLOTSON JOHNSON & PATTON CHASNOFF | STRIBLING, LLP 1201 Main Street, 1020 N.E. Loop 410, Suite 150 Suite 1300 San Antonio, Texas 78209 Dallas, Texas 75202 Telephone: (210) 469-4155 Telephone: (214) 382-3041 Facsimile: (214) 292-6564 Counsel for Appellants
Counsel for Counsel for Appellants Pecos Housing Finance Corporation, Cara Turn, Maribel Alvarez, and Irene Dominguez TO THE HONORABLE COURT OF APPEALS:
Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants
in the above-referenced matters file this unopposed motion for extension of time to
file Appellants’ opening briefs. Appellants’ opening briefs are currently due August 22,
2025. Appellants respectfully request a 14-day extension, until and including September
5, 2025.1 This is Appellants’ second request for an extension of time to file their opening
briefs.
I. Current Deadline
These appeals are from three separate interlocutory orders entered by the 348th
District Court of Tarrant County, in cause numbers 348-364430-25, 348-363561-25,
and 348-364135-25. The Clerk’s Records were filed July 1, 2025, and the Reporter’s
Records were filed July 3, 2025. Appellants were granted an initial extension of time to
file their opening briefs on July 15, 2025. On July 31, 2025 the Court issued a letter
informing the parties of an intended transfer to the Second Court of Appeals for
jurisdictional reasons. The Second Court of Appeals has not yet acknowledged or
accepted the transfer. Appellants’ briefs are currently due August 22, 2025.
II. Reasons for Extension
This is Appellants’ second request for an extension of time to file their opening
briefs. Appellants seek this extension due to the impending transfer of these cases to
1 Appellants have filed an Unopposed Motion to Consolidate Appeal Nos. 15-25-00110-CV, 15-25-00111-CV, and 15-25-
00112-CV. This motion seeks an extension of Appellants’ respective opening briefs in these appeals, but should this Court grant Appellants’ motion to consolidate, this motion applies to the deadline to file Appellants’ combined opening brief. the Second Court of Appeals and substantial conflicts with their counsel’s substantial
engagement in other matters with pressing deadlines, commitments, and ongoing work,
including the following:
• In re Marshall Fire Litigation, Case No. 2022CV30195, pending in the District Court of Boulder County, Colorado. Deposition held on August 13, 2025.
• Freight Essentials, LLC v. Globaltranz Enterprises, LLC, et al., Cause No. DC-23- 14235, pending in the 44th District Court of Dallas County, Texas. Summary judgment hearing on August 15, 2025.
• Jake Walker v. LG Operating Company, LLC, and Fernando de Leon, Cause No. DC- 22-05286, pending in the 191st District Court of Dallas County, Texas. Hearing on Plaintiff’s Motion for Reconsideration on August 15, 2025.
• Alake Williams and Carnell Williams, both Individually and as Next Friends of A.W., a minor, v. TK Elevator Corporation and H-E-B, LP, (formerly HEB Grocery Company), Case No. 2024-71972, pending in the 270th District Court of Harris County, Texas. Depositions held on August 18 and 19, 2025.
• Louis Moore v. National Collegiate Athletic Association, Cause No. DC-25-13153, pending in the 134th District Court of Dallas County, Texas. Mediation held August 19, 2025.
• In re Marshall Fire Litigation, Case No. 2022CV30195, pending in the District Court of Boulder County, Colorado. Hearing on multiple motions on August 20, 2025.
• Elm Creek Investments, LLC v. Monty Rial, et al., Cause No. DC-23-02616, pending in the 68th District Court of Dallas County, Texas. Hearing on Third-Party Plaintiffs’ Motion for Partial Summary Judgment on August 22, 2025.
• City of Dallas v. Dallas Police and Fire Pension System, Cause No. D-1-GN-24-004948, in the 353rd District Court of Tarrant County, Texas. Mediation scheduled for August 25, 2025. • Victor Vescovo v. Monika Vescovo, Cause No. 05-25-00615-CV, pending in the Fifth Court of Appeals in Dallas, Texas. Hearing on Motion to Require Payment of Costs on August 26, 2025.
• Canadian Breaks v. JP Morgan Chase, Case No. 2:21-CV-00037-M, pending in the United States District Court in the Northern Division of Dallas. Mediation scheduled for August 26, 2025.
• AECOM Technical Services, Inc., v. Pegasus Link Constructors, JV, et al., Cause No. DC-23-08147 pending in the 298th District Court of Dallas County, Texas. Hearing on Motions to Compel scheduled for August 27, 2025.
• Barbara J. Houser v. Allianz Global Risks US Insurance Company, et al., Cause No. 03- 23-01592-S pending in the United States District Court Northern District of Texas Dallas Division. Status Conference set for August 28, 2025.
• Linx Bar & Grill LLC d/b/a Linx Bar & Grill v. Isaac Sanchez, Cause No. 11-24- 00318-CV, pending in the Eleventh Court of Appeals in Eastland, Texas. Appellant’s Reply Brief due on August 28, 2025.
• Freight Essentials, LLC v. Globaltranz Enterprises, LLC, et al., Cause No. DC-23- 14235, pending in the 44th District Court of Dallas County, Texas. Hearing on Motion for Partial Summary Judgment on August 29, 2025.
• City of Dallas v. Dallas Police and Fire Pension System, Cause No. 08-25-00020-CV, pending in the Eighth Court of Appeals in El Paso, Texas. Appellant’s Reply Brief due on September 2, 2025.
• Jinhong Chen, et al. v. St. Mark’s School of Texas, Cause No. DC-22-10129, pending in the 101st District Court of Dallas County, Texas. Hearing on Motion to Compel Third-Party Forensic Exam or Alternative Motion for Spoliation on September 3, 2025.
• In re UMTH General Services, L.P., et al., No. 24-0024, pending in the Supreme Court of Texas. Oral Argument on September 9, 2025.
• Megatel Homes, LLC v. MM CCM 13MC, et al., Cause No. 05-24-01342-CV, pending in the Fifth Court of Appeals in Dallas, Texas. Appellant’s Reply Brief due on September 10, 2025. • Linx Food & Beverage, LLC, et al. v. GFE NY TWO, LLC, Cause No. 07-25- 00185-CV, pending in the Seventh Court of Appeals in Amarillo, Texas. Appellants’ Opening Brief due on September 22, 2025.
III. No Opposition
Appellees do not oppose the requested extension. This extension of time is
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ACCEPTED 15-25-00111-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/20/2025 2:52 PM Nos. 15-25-00110-CV; 15-25-00111-CV; 15-25-00112-CV CHRISTOPHER A. PRINE CLERK IN THE FIFTEENTH COURT OF APPEALS FILED IN AUSTIN, TEXAS 15th COURT OF APPEALS AUSTIN, TEXAS 8/20/2025 2:52:56 PM CHRISTOPHER A. PRINE PLEASANTON HOUSING FINANCE CORPORATION, ISMAEL GALLEGOS Clerk , JOEY MACON, MARK PINKSTON, ZACHARY PAWELEK, SCOTT FERGUSON, LILIAN CASHMER, AND BRANDON HICKS, APPELLANTS, V. CITY OF LAKE WORTH, TEXAS, APPELLEE.
PECOS HOUSING FINANCE CORPORATION, PLEASANTON HOUSING FINANCE CORPORATION, MAVERICK HOUSING FINANCE CORPORATION, LA VILLA HOUSING FINANCE CORPORATION, AND JOE DON BOBBITT, APPELLANTS, V. CITY OF ARLINGTON AND CITY OF FORT WORTH, APPELLEES.
PECOS HOUSING FINANCE CORPORATION, CARA TURN, MARIBEL ALVAREZ, AND IRENE DOMINGUEZ, APPELLANTS, V. CITY OF HALTOM CITY, TEXAS, APPELLEE.
UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ OPENING BRIEF
From the 348th District Court, Tarrant County, Texas Cause Nos. 348-364430-25, 348-363561-25, and 348-364135-25; Hon. Megan Fahey, presiding Jeffrey M. Tillotson Blake W. Stribling Texas Bar No. 20039200 Texas Bar No. 24070691 jtillotson@tillotsonlaw.com bstribling@chasnoffstribling.com Kathryn E. Yukevich Daniel J. Decavalier Texas Bar No. 24133390 Texas Bar No. 24129028 kyukevich@tillotsonlaw.com dlecavalier@chasnoffstribling.com TILLOTSON JOHNSON & PATTON CHASNOFF | STRIBLING, LLP 1201 Main Street, 1020 N.E. Loop 410, Suite 150 Suite 1300 San Antonio, Texas 78209 Dallas, Texas 75202 Telephone: (210) 469-4155 Telephone: (214) 382-3041 Facsimile: (214) 292-6564 Counsel for Appellants
Counsel for Counsel for Appellants Pecos Housing Finance Corporation, Cara Turn, Maribel Alvarez, and Irene Dominguez TO THE HONORABLE COURT OF APPEALS:
Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants
in the above-referenced matters file this unopposed motion for extension of time to
file Appellants’ opening briefs. Appellants’ opening briefs are currently due August 22,
2025. Appellants respectfully request a 14-day extension, until and including September
5, 2025.1 This is Appellants’ second request for an extension of time to file their opening
briefs.
I. Current Deadline
These appeals are from three separate interlocutory orders entered by the 348th
District Court of Tarrant County, in cause numbers 348-364430-25, 348-363561-25,
and 348-364135-25. The Clerk’s Records were filed July 1, 2025, and the Reporter’s
Records were filed July 3, 2025. Appellants were granted an initial extension of time to
file their opening briefs on July 15, 2025. On July 31, 2025 the Court issued a letter
informing the parties of an intended transfer to the Second Court of Appeals for
jurisdictional reasons. The Second Court of Appeals has not yet acknowledged or
accepted the transfer. Appellants’ briefs are currently due August 22, 2025.
II. Reasons for Extension
This is Appellants’ second request for an extension of time to file their opening
briefs. Appellants seek this extension due to the impending transfer of these cases to
1 Appellants have filed an Unopposed Motion to Consolidate Appeal Nos. 15-25-00110-CV, 15-25-00111-CV, and 15-25-
00112-CV. This motion seeks an extension of Appellants’ respective opening briefs in these appeals, but should this Court grant Appellants’ motion to consolidate, this motion applies to the deadline to file Appellants’ combined opening brief. the Second Court of Appeals and substantial conflicts with their counsel’s substantial
engagement in other matters with pressing deadlines, commitments, and ongoing work,
including the following:
• In re Marshall Fire Litigation, Case No. 2022CV30195, pending in the District Court of Boulder County, Colorado. Deposition held on August 13, 2025.
• Freight Essentials, LLC v. Globaltranz Enterprises, LLC, et al., Cause No. DC-23- 14235, pending in the 44th District Court of Dallas County, Texas. Summary judgment hearing on August 15, 2025.
• Jake Walker v. LG Operating Company, LLC, and Fernando de Leon, Cause No. DC- 22-05286, pending in the 191st District Court of Dallas County, Texas. Hearing on Plaintiff’s Motion for Reconsideration on August 15, 2025.
• Alake Williams and Carnell Williams, both Individually and as Next Friends of A.W., a minor, v. TK Elevator Corporation and H-E-B, LP, (formerly HEB Grocery Company), Case No. 2024-71972, pending in the 270th District Court of Harris County, Texas. Depositions held on August 18 and 19, 2025.
• Louis Moore v. National Collegiate Athletic Association, Cause No. DC-25-13153, pending in the 134th District Court of Dallas County, Texas. Mediation held August 19, 2025.
• In re Marshall Fire Litigation, Case No. 2022CV30195, pending in the District Court of Boulder County, Colorado. Hearing on multiple motions on August 20, 2025.
• Elm Creek Investments, LLC v. Monty Rial, et al., Cause No. DC-23-02616, pending in the 68th District Court of Dallas County, Texas. Hearing on Third-Party Plaintiffs’ Motion for Partial Summary Judgment on August 22, 2025.
• City of Dallas v. Dallas Police and Fire Pension System, Cause No. D-1-GN-24-004948, in the 353rd District Court of Tarrant County, Texas. Mediation scheduled for August 25, 2025. • Victor Vescovo v. Monika Vescovo, Cause No. 05-25-00615-CV, pending in the Fifth Court of Appeals in Dallas, Texas. Hearing on Motion to Require Payment of Costs on August 26, 2025.
• Canadian Breaks v. JP Morgan Chase, Case No. 2:21-CV-00037-M, pending in the United States District Court in the Northern Division of Dallas. Mediation scheduled for August 26, 2025.
• AECOM Technical Services, Inc., v. Pegasus Link Constructors, JV, et al., Cause No. DC-23-08147 pending in the 298th District Court of Dallas County, Texas. Hearing on Motions to Compel scheduled for August 27, 2025.
• Barbara J. Houser v. Allianz Global Risks US Insurance Company, et al., Cause No. 03- 23-01592-S pending in the United States District Court Northern District of Texas Dallas Division. Status Conference set for August 28, 2025.
• Linx Bar & Grill LLC d/b/a Linx Bar & Grill v. Isaac Sanchez, Cause No. 11-24- 00318-CV, pending in the Eleventh Court of Appeals in Eastland, Texas. Appellant’s Reply Brief due on August 28, 2025.
• Freight Essentials, LLC v. Globaltranz Enterprises, LLC, et al., Cause No. DC-23- 14235, pending in the 44th District Court of Dallas County, Texas. Hearing on Motion for Partial Summary Judgment on August 29, 2025.
• City of Dallas v. Dallas Police and Fire Pension System, Cause No. 08-25-00020-CV, pending in the Eighth Court of Appeals in El Paso, Texas. Appellant’s Reply Brief due on September 2, 2025.
• Jinhong Chen, et al. v. St. Mark’s School of Texas, Cause No. DC-22-10129, pending in the 101st District Court of Dallas County, Texas. Hearing on Motion to Compel Third-Party Forensic Exam or Alternative Motion for Spoliation on September 3, 2025.
• In re UMTH General Services, L.P., et al., No. 24-0024, pending in the Supreme Court of Texas. Oral Argument on September 9, 2025.
• Megatel Homes, LLC v. MM CCM 13MC, et al., Cause No. 05-24-01342-CV, pending in the Fifth Court of Appeals in Dallas, Texas. Appellant’s Reply Brief due on September 10, 2025. • Linx Food & Beverage, LLC, et al. v. GFE NY TWO, LLC, Cause No. 07-25- 00185-CV, pending in the Seventh Court of Appeals in Amarillo, Texas. Appellants’ Opening Brief due on September 22, 2025.
III. No Opposition
Appellees do not oppose the requested extension. This extension of time is
sought so that justice may be done in the disposition of this case and is not sought for
purposes of delay.
PRAYER
For these reasons, Appellants respectfully request that this Motion for Extension
of Time be granted and that the Court extend the time for filing their opening briefs
until and including September 5, 2025. Appellants further request all such other relief
to which they may be justly entitled. Dated: August 20, 2025 /s/ Jeffrey M. Tillotson Jeffrey M. Tillotson Texas Bar No. 20039200 jtillotson@tillotsonlaw.com Kathryn E. Yukevich State Bar No. 24133390 kyukevich@tillotsonlaw.com TILLOTSON JOHNSON & PATTON 1201 Main Street, Suite 1300 Dallas, Texas 75202 Telephone: (214) 382-3041 Facsimile: (214) 292-6564
Counsel for Counsel for Appellants Pecos Housing Finance Corporation, Cara Turn, Maribel Alvarez, and Irene Dominguez
Blake W. Stribling Texas Bar No. 24070691 bstribling@chasnoffstribling.com Daniel J. Lecavalier Texas Bar No. 24129028 dlecavalier@chasnoffstribling.com CHASNOFF STRIBLING, LLP 1020 N.E. Loop 410, Suite 150 San Antonio, Texas 78209 Telephone: (210) 469-4155
Counsel for Appellants CERTIFICATE OF CONFERENCE
I certify that, on August 20, 2025, I conferred with Appellees’ counsel, who
stated Appellees are unopposed to the relief requested.
/s/ Kassi Yukevich Kassi Yukevich
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument was
forwarded to all counsel of record in accordance with the Texas Rules of Appellate
Procedure on August 20, 2025.
/s/ Jeffrey M. Tillotson Jeffrey M. Tillotson 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.
Jeffrey Tillotson on behalf of Jeffrey M. Tillotson Bar No. 20039200 swade@tillotsonlaw.com Envelope ID: 104628371 Filing Code Description: Motion Filing Description: UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS OPENING BRIEF Status as of 8/20/2025 3:02 PM CST
Associated Case Party: Pecos Housing Finance Corporation
Name BarNumber Email TimestampSubmitted Status
Jeffrey MTillotson jtillotson@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
Kassi Yukevich kyukevich@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
Amanda Reichek areichek@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
Blake W.Stribling bstribling@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT
Daniel J.Lecavalier dlecavalier@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT
Nathaniel Buchheit nbuchheit@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
Associated Case Party: City of Arlington, Texas
Name BarNumber Email TimestampSubmitted Status
Nena Chima-Tetteh nena.chima-tetteh@arlingtontx.gov 8/20/2025 2:52:56 PM SENT
Joseph N.Nguyen joseph.nguyen@arlingtontx.gov 8/20/2025 2:52:56 PM SENT
Jonathan Moss jonathan.moss@arlingtontx.gov 8/20/2025 2:52:56 PM SENT
Alexander J.Lindvall alexander.lindvall@arlingtontx.gov 8/20/2025 2:52:56 PM SENT
Galen Gatten galen.gatten@arlingtontx.gov 8/20/2025 2:52:56 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Kim Decker kdecker@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT
Rachel Feltner rfeltner@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT
Kira Lytle klytle@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
Christopher Schluter cschluter@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT 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.
Jeffrey Tillotson on behalf of Jeffrey M. Tillotson Bar No. 20039200 swade@tillotsonlaw.com Envelope ID: 104628371 Filing Code Description: Motion Filing Description: UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS OPENING BRIEF Status as of 8/20/2025 3:02 PM CST
Case Contacts
Christopher Schluter cschluter@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT
Julie Whitson jwhitson@chasnoffstribling.com 8/20/2025 2:52:56 PM SENT
Sean Wallace swallace@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
TJP Service tillotsonjohnsonpatton@gmail.com 8/20/2025 2:52:56 PM SENT
Devlin Browne dbrowne@tillotsonlaw.com 8/20/2025 2:52:56 PM SENT
Associated Case Party: City of Fort Worth, Texas
Name BarNumber Email TimestampSubmitted Status
Stephen Cumbie stephen.cumbie@fortworthtexas.gov 8/20/2025 2:52:56 PM SENT
Christopher Mosley chris.mosley@fortworthtexas.gov 8/20/2025 2:52:56 PM SENT
Olyn Poole olyn.poole@fortworthtexas.gov 8/20/2025 2:52:56 PM SENT