SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 1

NO. 05-14-00874-CV

IN THE COURT OF APPEALS 

FOR THE FIFTH DISTRICT OF TEXAS 

AT DALLAS 

HASSAN PARSA, 

Appellant, 

v. 

VINCENT WALKER, 

Appellee.

 

On Appeal from Cause No. DC-13-11870 

14th Judicial District Court, Dallas Couty, Texas

Hon. Eric Moyé, Judge Presiding 

 

SECOND MOTION FOR EXTENSION OF TIME 

TO FILE BRIEF OF APPELLANT 

 

TO THE HONORABLE COURT OF APPEALS:

COMES NOW, Appellant Hassan Parsa, respectfully moves this Honorable Court 

for a second extension of time in which to file his brief, stating as follows: 

1. The court below is the 14th District Court, Dallas County, Texas.

2. This is an appeal from an order dated June 9, 2014. 

3. A notice of appeal was timely filed on July 3, 2014. The Clerk’s Record 

was filed on August 5, 2014. The Reporter’s Record was filed July 25, 2014. 

ACCEPTED

05-14-00874-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

5/18/2015 10:26:54 AM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 5/18/2015 10:26:54 AM LISA MATZ Clerk
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 2

4. By order dated August 25, 2014, this appeal was abated due to the 

bankruptcy of Appellant. By order dated March 18, 2015, the stay was lifted by this 

Court and Appellant’s brief was due to be filed April 15, 2015.

5. By Order dated April 15, 2015, pursuant to extension, Appellant’s Brief is 

currently due to be filed with this Court on May 17, 2015.

6. It is impossible to adequately prepare the brief of Appellant in the current 

time allowed. Although counsel for Appellant was counsel in the trial court, the delay 

caused by the bankruptcy has caused the record to go cold, and it must be thoroughly rereviewed. Further, counsel’s spouse had surgery on March 30, 2015, leaving her 

incapacitated for a period of two months. During this period counsel has also had to 

prepare and file a Reply to Response to Petition for Review in the Supreme Court (filed 

April 30, 2015) in Goodwin v. QuikTrip Corp., No. 14-1076. Counsel for Appellant

requests additional time to adequately prepare the brief of Appellant in the current time 

allotted.

7. The extension sought in this motion is not sought solely for purposes of 

delay, but only so that justice may be done.

8. Counsel for Appellee was asked if he opposed this motion on Thursday, 

May 14, 2015. As of Monday, May 18, 2015, no response has been received.

9. An extension of thirty (30) days is sought by this motion.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests

that the time in which he may file his Brief be extended to and including June 15, 2015, 

and for such other and further relief to which he may be entitled at law or in equity.
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 3

Respectfully submitted,

 /s/ Mark Donheiser

RANDAL MATHIS

State Bar No. 13194300

MARK DONHEISER

State Bar No. 05974800

MATHIS & DONHEISER

1412 Main Street, Suite 2600

Dallas, TX 75202

Telephone: 214.303.1919

Facsimile: 214.303.0399

ATTORNEYS FOR HASSAN PARSA

CERTIFICATE OF CONFERENCE

Counsel for Appellee, Jerrod David, has not responded to a May 14, 2015 request 

for conference on this motion

Signed this 18

th day of May, 2015.

 /s/ Mark Donheiser

MARK DONHEISER
SECOND MOTION TO FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT PAGE 4

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing document has 

been forwarded to all other known counsel of record as listed below, via facsimile, in 

accordance with the Texas Rules of Civil Procedure on this 18

th day of May, 2015.

Mr. Jerrod L. Davis

Brady & Brady, PLLC

6440 N. Central Expressway, Suite 610

Dallas, Texas 75206

 /s/ Mark Donheiser

MARK DONHEISER