NO. 05-14-01415-CV 

IN THE FIFTH COURT OF APPEALS 

DALLAS, TEXAS 

SOUTHAMPTON LTD. and SOUTHWEST REINSURANCE, INC. 

Appellants, 

vs. 

FOUR HORSEMEN AUTO GROUP, INC., CHISHOLM TRAIL AUTO 

GROUP, LLC, CHISHOLM TRAIL AUTO GROUP II, LLC, 

CHISHOLM TRAIL REAL ESTATE, LLC 

Appellees. 

ON APPEAL FROM THE 101st DISTRICT COURT 

OF DALLAS COUNTY, TEXAS, NO. DC-13-13331 

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME 

IN WHICH TO FILE REPLY IN SUPPORT OF APPEAL 

Werner A. Powers 

State Bar No. 16218800 

Natalie DuBose 

 State Bar No. 24077481 

HAYNES AND BOONE, LLP 

2323 Victory Avenue, Suite 700

 Dallas, Texas 75219 

214-651-5000 

214-651-5940 (facsimile) 

ATTORNEYS FOR APPELLANTS 

ACCEPTED

05-14-01415-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

2/26/2015 3:27:42 PM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 2/26/2015 3:27:42 PM LISA MATZ Clerk
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To the Honorable Fifth Court of Appeals: 

Pursuant to Texas Rule of Appellate Procedure 10.5(b), Appellants file 

this Unopposed Motion for Extension of Time in Which to File a Reply in 

Support of their Appeal and hereby request the Court extend the deadline by 

which to file a reply in support of their appeal by two (2) weeks, or until March 

17, 2015. In support of their Motion, Appellants would show the Court the 

following: 

1. Appellants’ Reply is currently due on Tuesday, March 3, 2015. 

2. No previous motions for extensions have been made. 

3. Appellants seek an extension so that it may adequately address 

Appellees’ evidentiary and substantive arguments, the response to which 

requires detailed research and briefing. Counsel is in the process of preparing 

the Reply, but in the interest of completing it correctly and thoroughly, 

Appellants seek an additional two seeks in which to respond. 

4. Appellees have no objection to this extension. 

IV. PRAYER

For these reasons, Appellants respectfully request that the Court extend 

the deadline by which Appellants must file their reply in support of their appeal 

for two (2) weeks, or until March 17, 2015. 

 
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Respectfully submitted, 

HAYNES AND BOONE, LLP 

/s/ Werner A. Powers 

Werner A. Powers 

State Bar No. 16218800 

Natalie DuBose 

State Bar No. 24077481 

2323 Victory Avenue, Suite 700 

Dallas, Texas 75219 

Telephone: (214) 651-5000 

Telecopier: (214) 651-5940 

werner.powers@haynesboone.com 

natalie.dubose@haynesboone.com 

ATTORNEYS FOR APPELLANTS 

SOUTHAMPTON, LTD. AND 

SOUTHWEST REINSURANCE, INC. 

 
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CERTIFICATE OF SERVICE 

This certifies that a true and correct copy of the foregoing instrument has 

been sent to all counsel of record to the appeal in accordance with the Texas 

Rules of Civil Procedure on this 26th day of February, 2015. 

James J. Doyle III 

The Doyle Law Firm 

4054 McKinney Ave., Suite 310 

Dallas, Texas 75204 

james@doylelawonline.com 

Additionally, a courtesy copy has been provided to the following 

attorneys: 

Mark A. Shank Leonard (Ladd) A. Hirsch 

Gruber Hurst Johansen Hail Shank James D. Sheppard 

1445 Ross Avenue, Suite 2500 Diamond McCarthy, LLP 

Dallas, Texas 75202-2711 1201 Elm Street Suit, 3400 

mshank@ghjhlaw.com Dallas, Texas 75209 

 LHirsch@diamondmccarthy.com 

 

 /s/ Natalie DuBose 

 Natalie DuBose 

15048542_1