Shore Chan DePumpo LLP and Edward Mandel v. Steven W. Thrasher D/B/A Thrasher Associates, L.L.C.

• Court: Court of Appeals of Texas
• Decided: February 24, 2015
• Docket: 05-14-00967-CV
• Status: Published

Opinion

ACCEPTED 05-14-00967-cv FIFTH COURT OF APPEALS DALLAS, TEXAS 2/24/2015 1:01:22 PM LISA MATZ CLERK

CASE NO. 05-14-00967-CV

IN THE FIFTH DISTRICT COURT OF APPEALS FILED IN DALLAS, TEXAS 5th COURT OF APPEALS DALLAS, TEXAS 2/24/2015 1:01:22 PM LISA MATZ SHORE CHAN DEPUMPO LLP AND EDWARD MANDEL Clerk

v.

STEVEN W. THRASHER D/B/A THRASHER ASSOCIATES L.L.C.

On Appeal from the 193rd Judicial District Court Dallas County, Texas Trial Court Cause No. DC-13-10549

AGREED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF

Respectfully submitted,

Michael W. Shore Texas Bar No. 18294915 Russell J. DePalma Texas Bar No. 00795318 SHORE CHAN DEPUMPO LLP Bank of America Plaza 901 Main Street, Suite 3300 Dallas, Texas 75202 214-593-9110 Telephone 214-593-9111 Facsimile

Attorneys for all Appellants TO THE HONORABLE FIFTH COURT OF APPEALS:

Shore Chan DePumpo LLP and Edward Mandel (collectively the

“Appellants”), hereby move this Court to extend the time to file their reply brief by

7 days. Appellants have conferred with counsel for the Appellees and Appellees

have agreed to this motion for an extension. In further support of this motion, the

Appellants assert the following:

1. Current Deadline March 2, 2015. The reply brief for the Appellants is

due on March 2, 2015.

2. Length of Extension: 7 days. The Appellants respectfully request an

extension of the current deadline be enlarged by 7 days to file their brief

so that the new due date would be March 9, 2015.

3. Basis for Extension: The Appellants request additional time for briefing

due to the schedules of their counsel. The extension is not sought for

delay but to ensure justice can be done.

4. Agreed Upon Motion: As noted above, counsel for Appellees has

agreed to the Appellants’ request for a 7-day extension. It would not be

prejudicial for this court to grant the motion.

WHEREFORE, for the foregoing reasons, the Appellants respectfully pray

that this Court grant their motion for an extension of time to file their brief so that the new deadline will be March 9, 2015. The Appellants pray for any other relief

to which they may be entitled.

/s/ Michael W. Shore Michael W. Shore Texas Bar No. 18294915 Russell J. DePalma Texas Bar No. 00795318 SHORE CHAN DEPUMPO LLP Bank of America Plaza 901 Main Street, Suite 3300 Dallas, Texas 75202 214-593-9110 Telephone 214-593-9111 Facsimile

Attorneys for all Appellants CERTIFICATE OF CONFERENCE

On February 20, 2015, the undersigned counsel conferred with counsel for

Appellees, Steven Ramos, to request whether counsel would agree to a 7-day

extension. Counsel for the Appellees agreed.

_/s/Russell DePalma Russell DePalma

CERTIFICATE OF SERVICE

The undersigned hereby certifies that the within document has been served

via facsimile on this 24th day of February, 2015.

W. Randall Ackerman Steven Ramos Ackerman & Savage, L.L.C. 8226 Douglas Avenue, Suite 330 Dallas, TX 75225

/s/Russell J. DePalma Russell J. DePalma