Playa Vista, L.P., Morgan- Multi Family LLC, and Scott Morgan v. Lakeside Re, L.P., GSRE, Inc., and Avi Ron

Opinion

ACCEPTED 01-14-00871-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 3/24/2015 11:25:02 AM CHRISTOPHER PRINE CLERK

No. 01-14-00871-CV

PLAYA VISTA LP, MORGAN- § FILED IN 1st COURT OF APPEALS MULTI FAMILY LLC, and SCOTT § HOUSTON, TEXAS MORGAN § 3/24/2015 11:25:02 AM Appellant § CHRISTOPHER A. PRINE § Clerk v. § § COURT OF APPEALS OF TEXAS LAKESIDE RE, LP, GSRE, INC., § and, AVI RON § FIRST DISTRICT Appellee §

UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLATE BRIEF

Appellants, Playa Vista LP, Morgan-Multi Family LLC, and Scott Morgan,

asks the Court to extend the time to file their Appellate Brief.

Introduction

1. This motion is filed before the Appellate Brief is due. There is no specific

deadline to file this motion to extend time. See Tex. R. App. Proc. 38.6(d).

2. Appellees are unopposed.

Argument & Authorities

3. The Court may grant an extension of time under Texas Rule of Appellate

Procedure 38.6(d) and 10.5(b).

4. The deadline to file the Appellate Brief is March 30, 2015. Appellants request

an additional twenty-one (21) days to file the Appellate Brief, extending the

deadline to Monday, April 20, 2015. 5. Appellants’ counsel had two unforeseen personal emergencies arise over a two

and a half week period.

6. An extension/stay was previously requested due to summary judgment hearings

in the 270th Judicial District Court of Harris County in this cause, causing the

case to be abated. The appeal was reinstated in January. One extension has

been previously granted. This is Appellants’ second request for an extension.

Conclusion and Prayer

7. For the reasons stated above, Appellants ask the Court to grant an extension of

time to file the Appellate Brief until April 20, 2015.

Respectfully Submitted,

PARANJPE & MAHADASS LLP

/s/ Tej Paranjpe___________ Tej R. Paranjpe State Bar Number: 24071829 3701 Kirby, Suite 530 Houston, Texas 77098 832.667.7700 Telephone 832.202.2018 Facsimile tparanjpe@pandmllp.com ATTORNEY FOR APPELLANTS CERTIFICATE OF CONFERENCE

I certify that I have conferred with opposing counsel, Jerry Hecht, by email, and he is unopposed to Appellant’s Motion to Extend Time to File Appellate Brief.

/s/ Tej Paranjpe_________ TEJ R PARANJPE

CERTIFICATE OF SERVICE

I hereby certify that, in accordance with Rule 9.5 of the Texas Rules of Appellate Procedure, I have served the foregoing document upon the following parties by facsimile or email correspondence:

Jerry Hecht trialatt@aol.com

Dated: March 24, 2015