No. 14

- 14 -00169- CV

In the Court of Appeals for the Fourteenth Court of Appeals District a t Houston

Kyle Tauch, Tranquility Apartments General Corporation and Tranquility Apartments, Ltd., Appellants/Cross-Appellees,

v.

Joel R. Scott, Appellee/Cross-Appellant.

Appeal from the 80 th Judicial District Court of Harris County, Texas

Trial Court Cause No. 2011-21305

Unopposed First Motion for Extension of Time to File Reply Brief of Cross-Appellant

T O T HE H ONORABLE C OURT OF A PPEALS :

Appellee/Cross-Appellant, Joel R. Scott, respectfully files this Unopposed

First Motion for Extension of Time to File his Reply Brief of Cross-Appellant.

1. The present deadline for filing the reply brief is June 8, 2015.

2. Appellee/Cross-Appellant seeks a tw o-week extension, until June 22

,

2015, in which to file his reply brief. ACCEPTED 14-14-00169-CV FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS 6/8/2015 11:01:06 AM CHRISTOPHER PRINE

CLERK2

3. This is Appell ee/Cross

- Appellant ’ s first request for an extension of

time to file t h e brief

.

4. This motion is unopposed.

5. Appell ee/Cross

- Appellant needs the additional time t o file his brief

with this Court for the following reasons:

Lead a ppellate counsel, Chad Flores, has been engaged in other litigation

with imminent deadlines that have prevented him from completing the reply brief

before the deadline, including, but not l imited to, the following:

 Assistance in preparation of a petitioners’ brief on the merits in No.
14

- 0507, Ineos USA, LLC v. Elmgren , in the Supreme Court of Texas. The petitioners’ brief was filed May 22, 2015.

 Assistance in preparation of a petitioner’ s brief on the merits in No.
14

- 0894, Meritage Homes of Texas, L.L.C. v. Ruan , in the Supreme Court of Texas. The petitioner’s brief was filed on June 1, 2015.

 Preparation of a real party in interest’s brief on the merits in No.
14

- 0804, In re Seneca Res ources Corp. , in the Supreme Court of Texas. The real party in interest’s brief on the merits is due to be filed on or before June 22, 2015.

 Assistance in preparation of a reply brief in No. 14

- 20717, Forum Subsea Rentals v. Elsharhawy , in the United Sta tes Court of Appeals for the Fifth Circuit. The appellants’ reply is due to be filed on or before June 22, 2015.

 Assistance in preparation of a petitioner’s reply in support of a petition for review in No. 14

- 0971, Clef Construction, Inc. v. CCV Holdings , LLC , in the Supreme Court of Texas. The petitioner’s reply is due to be filed on or before June 22, 2015.3

 Preparation of a brief of appellee in No. 01

- 15

- 232

- CV, Nation wide Distribution Services, Inc. v. Jones , in the Court of Appeals for the
First D istrict of Texas. The brief of appellee is due to be filed on or before June 29, 2015.

 Preparation of responses to five motions for summary judgment in In re West Explosion Cases ( City of West v. CF Industries Sales, LLC ),
in the 170th District Court of McLennan County. The responses are due to be filed on or before July 8, 2015.

6. This motion is not filed for the purpose of delay, but to allow counsel

adequate time to prepare the cross

- appellant ’ s reply brief

.

P RAYER FOR R ELIEF

For these reasons, Appell ee /Cross

- Appellant respectfully request s that this

Court grant him an extension of time to file his reply brief until June 22 , 201 5

.

Respectfully submitted,

BECK REDDEN LLP

By: /s/ Chad Flores
Chad Flores
State Bar No. 24059759 1221 McKinney, Suite 4500 Houston, Texas 77010
713.951.3700 713.951.3720 (Fax)
cflores@beckredden.com

Attorneys for Appell ee/Cross

- Appellant

, Joel R. Scott4 Certificate of Conference

I certify that I conferred with a ppel late counsel for Appell ant , who does not oppose the requested extension.

/s/ Chad Flores
Chad Flores

Certificate of Service

A true and correct copy of the above and foregoing motion was properly forwarded to counsel of record for Appell ant in accorda nce with Texas Rules of Appellate Procedure 9.5 by the e

- file service provider on this the 8 th day of June

, 201 5

, addressed as follows:

Michele Barber Chimene
The Chimene Law Firm 15203 Newfield Bridge Lane Sugar Land, TX 77498
michelec@airmail.net

Couns el for Appellants /Cross

- Appellees Kyle Tauch, Tranquility Apartments

General Corporation and Tranquil i ty Apartments, Ltd.

/s/ Chad Flores
Chad Flores