CJAMES\001630\00065\1334041.1 

NO. 01-14-00907-CV 

IN THE FIRST COURT OF APPEALS 

HOUSTON, TEXAS 

________________________________________________ 

CRUM & FORSTER SPECIALTY INSURANCE COMPANY, 

Appellant 

vs. 

CREEKSTONE BUILDERS, INC. et. al., 

Appellees

______________________________________ 

On Appeal from the 215th Judicial District Court of Harris County, Texas 

Trial Court Case No. 2014-29616, Honorable Elaine Palmer, Presiding 

APPELLEES’ UNOPPOSED FIRST MOTION FOR 

EXTENSION OF TIME TO FILE APPELLEE’S BRIEF 

TO THE HONORABLE FIRST COURT OF APPEALS: 

 Appellees Creekstone Builders, Inc., Nashville Creekstone, LLC, Steven 

Keller, Everett Jackson and Creekstone SC I, LLC (collectively referred to as 

“Appellees”) file this Unopposed First Motion for Extension of Time to File 

Appellee’s Brief and would respectfully show: 

1. This Motion seeks a thirty (30) day extension of time to file 

Appellee’s Brief. The current deadline to file Appellee’s Brief is February 16, 

ACCEPTED

01-14-00907-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

2/12/2015 5:34:47 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 2/12/2015 5:34:47 PM CHRISTOPHER A. PRINE Clerk
CJAMES\001630\00065\1334041.1 

2015. Thus, Appellee seeks an extended deadline to March 18, 2015. See Tex. R. 

App. P. 38.6(d); 10.1, 10.3 and 10.5(b). 

2. This is Appellee’s first request for an extension of time to file their 

Brief. 

3. Counsel for Appellees has conferred with counsel for Appellant, and 

counsel for Appellant is not opposed to this Motion for Extension of Time to File 

Appellee’s Brief. 

4. Appellee’s respectfully request an extension of time because it is 

necessary to ensure their Brief is adequately prepared. Appellant had previously 

been granted a thirty (30) day extension to file their Brief by agreement of the 

parties and order of this Court, and thus is agreeable to reciprocating to Appellees. 

5. Appellees have been diligent in connection with this appeal and have 

not caused any delay. Appellees submit that this requested extension is reasonable. 

For these reasons, Appellees respectfully request that the Court grant this 

Motion and extend the deadline to file Appellee’s Brief for a period of thirty (30) 

days until March 18, 2015, and grant any other relief to which it is justly entitled. 
CJAMES\001630\00065\1334041.1 

Respectively submitted,

 

 BOYARMILLER, PC 

By: /s/ Chris T. James 

 Matthew S. Veech 

 State Bar No. 24000372 

 Chris T. James 

 State Bar No. 24069987 

 Boyar Miller 

 4265 San Felipe Road, Suite 1200 

 Houston, Texas 77027 

 (713) 850-7766 Telephone 

 (713) 552-1758 Facsimile 

 Justin Lucey 

 South Carolina Bar No. 15438 

 Justin O’Toole Lucey, P.A. 

 415 Mill Street 

 Mt. Pleasant, SC 29464 

 (843) 849-8400 Telephone 

 (843) 849-8406 Facsimile 

 Admitted Pro Hac Vice

 
CJAMES\001630\00065\1334041.1 

CERTIFICATE OF SERVICE 

 I hereby certify that a true and correct copy of this Appellee’s Unopposed 

First Motion for Extension of Time to File Appellee’s Brief was served on the 

following counsel for the Appellant pursuant to the Texas Rules of Appellate 

Procedure on this 12th day of February, 2015. 

Brian S. Martin 

Rodrigo “Diego” Garcia 

Christopher H. Avery 

Thompson, Coe, Cousins & Irons, LLP 

One Riverway, Suite 1400 

Houston, TX 77056 

(713) 403-8210 Telephone 

(713) 403-8299 Facsimile 

 /s/ Chris T. James___________ 

 Chris T. James 

 
CJAMES\001630\00065\1334041.1 

CERTIFICATE OF CONFERENCE 

Counsel for Appellees conferred with counsel for Appellant on February 12, 

2015 regarding the relief requested in this Motion and Counsel for Appellant is not 

opposed to this Motion. 

 /s/ Chris T. James___________ 

 Chris T. James