NO. 03-15-00498-CV 

IN THE COURT OF APPEALS

FOR THE THIRD DISTRICT OF TEXAS

LONG CANYON PHASE II AND III HOMEOWNERS 

ASSOCIATION, INC., 

Appellant, 

v.

CHRIS CASHION AND LISA CASHION, 

Appellee. 

Appealed from the County Court at Law No. 2 of Travis County, 

Texas, 

Cause No. C-1-CV-15-001016

APPELLANT LONG CANYON PHASE II AND III 

HOMEOWNERS ASSOCIATION, INC.’S FIRST MOTION 

FOR EXTENSION OF TIME TO FILE APPELLANT BRIEF

TO THE HONORABLE COURT:

Appellant Long Canyon Phase II and III Homeowners 

Association, Inc. (“Appellant”), files this First Motion for 

Extension of Time to File Appellant’s Brief pursuant to Texas 

Rules of Appellate Procedure 38.6(d) and 10.5(b)(1) and would 

respectfully show unto the Court the following: 

ACCEPTED

03-15-00498-CV

6873283

THIRD COURT OF APPEALS

AUSTIN, TEXAS

9/10/2015 4:05:07 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 9/10/2015 4:05:07 PM JEFFREY D. KYLE Clerk
2

1. The deadline for filing Appellant’s Brief is today,

September 10, 2015.

2. Appellant seeks a 21-day extension of time to file 

Appellant’s Brief. Appellant respectfully requests that the Court 

extend the deadline for filing Appellant’s Brief to October 1, 2015.

3. This is the first Motion for Extension of Time filed for 

Appellant’s Brief with the Court.

4. This extension of time is not requested for mere delay, 

but to allow Appellant adequate time to prepare Appellant’s Brief.

5. Appellant is requesting additional time in order to 

thoroughly research and adequately brief these matters for the 

Court.

For these reasons, Appellant respectfully requests that this 

Court grant a 21-day extension of time to file Appellant’s Brief. 

Appellant also requests any further relief to which it may be 

entitled.
3

Respectfully submitted,

Roberts Markel Weinberg Butler Hailey PC

_______________________________

FRANK O. CARROLL III

Texas State Bar No. 24082785

DAWN S. HOLIDAY

Texas State Bar No. 24046090

Amy M. VanHoose

Texas State Bar No. 24042085

2800 Post Oak Blvd., 57th Floor

Houston, Texas 77056

Telephone: 713-840-1666

Facsimile: 713-840-9404

fcarroll@rmwbhlaw.com

dholiday@rmwbhlaw.com

avanhoose@rmwbhlaw.com

ATTORNEYS FOR APPELLANT, 

LONG CANYON PHASE II AND III 

HOMEOWNERS ASSOCIATION, INC.
4

CERTIFICATE OF CONFERENCE

I hereby certify that on September 10, 2015, I conferred with 

William C. Davidson regarding the merits of this First Motion for 

Extension of Time. Mr. Davidson informed me that he was 

unopposed to the filing of this First Motion for Extension of Time.

_________________________________

FRANK O. CARROLL III

CERTIFICATE OF COMPLIANCE

I hereby certify that this document is 463 words, as 

calculated by the word count feature of Microsoft Word 2007

(Professional Edition).

_________________________________

FRANK O. CARROLL III
5

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing 

instrument was served upon the parties listed below by facsimile, 

messenger, regular U.S. Mail, certified mail, return receipt 

requested and/or electronic service in accordance with the Texas 

Rules of Appellate Procedure on this the 10th day of September, 

2015.

William C. Davidson 

bdavidson@chmc-law.com

Chamberlain McHaney 

P.O. Box 684158 

301 Congress, 21st Floor 

Austin, Texas 79701 

_____________________________________

Frank O. Carroll III