NO. 03-15-00051-CV

IN THE COURT OF APPEALS

THIRD COURT OF APPEALS DISTRICT

AUSTIN, TEXAS

TRENT LINDIG, 

 Appellant

v.

PLEASANT HILL ROCKY COMMUNITY CLUB 

 Appellee 

ON APPEAL FROM THE 33RD DISTRICT COURT, BLANCO COUNTY, TEXAS

HONORABLE J. ALLAN GARRETT PRESIDING

CAUSE NO. CV07580

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO 

FILE APPELLANT’S BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS: 

Appellant respectfully presents this unopposed first motion to extend 

the time in which to file their Appellant’s Brief pursuant to Texas Rule of 

Appellate Procedure 38.6. No previous motions for extension of time to file 

the Appellant’s Brief have been filed. In support of this motion, appellant 

would show the Court as follows:

ACCEPTED

03-15-00051-CV

4327723

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/2/2015 10:47:37 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/2/2015 10:47:37 AM JEFFREY D. KYLE Clerk
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I.

Appellant’s principal brief is currently due on March 16, 2015. 

Because of the events and matters described more fully below, appellant

requests an extension of an additional 30 days in which to file the

Appellant’s Brief or until April 15, 2015.

II.

The requested extension is necessary because the following matters 

have prevented the undersigned from completing the Appellant’s Brief and 

will preclude the undersigned from doing so sooner than April 15, 2015:

1. The undersigned is preparing a reply brief in Philip Wayne 

Hindes and Melinda Hindes Eustace v. La Salle County et al., No. 04-14-00651-CV, which is currently due on March 27, 2015;

2. The undersigned prepared motions to exclude evidence in order 

to meet a pretrial deadline in Martha Elvia Bolanos et al. v. 

General Motors et al., No. 7,478, in the 49th Judicial District 

Court, Zapata County, Texas;

3. The undersigned will be conducting legal research and related 

tasks to prepare for an oral argument to be conducted in City of 

San Antonio v. Casey Industrial, Inc. and Wheelbrator Air 

Pollution Control, Inc., No. 04-14-00429-CV, which will be held 

on April 2, 2015; and

4. The undersigned was nominated to run for President-Elect of 

the Texas Young Lawyers Association and has had expended 

considerable time preparing for the campaign and will be 

conducting a state-wide campaign during the month of March.

For all of the reasons explained above, counsel for appellant cannot 

complete the Appellant’s Brief by its current due date of March 16, 2015, 

and needs an additional 30 days in which to do so.
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III.

On March 2, 2015, the undersigned conferred with Jeff Small, lead 

appellate counsel for appellees. Mr. Small indicated that this motion would 

not be opposed.

WHEREFORE, PREMISES CONSIDERED, appellant respectfully 

request that this Court grant his motion for extension of time in which to file 

the Appellant’s Brief, extend the deadline in which to file the brief an 

additional 30 days up to and including April 15, 2015, and grant such other 

and further relief to which appellant may be justly and equitably entitled.

Respectfully submitted,

/s/ Samuel V. Houston, III

SAMUEL V. HOUSTON,III

State Bar No. 24041135

HOUSTON DUNN, PLLC

4040 Broadway, Suite 440

San Antonio, Texas 78209

Telephone: (210) 775-0882

Fax: (210) 826-0075

sam@hdappeals.com

ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE

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

has been served on the following counsel in accordance with the Texas Rules 

of Appellate Procedure, on the 2nd day of March, 2015:

Jeff D. Small Via email/e-service

LAW OFFICE OF JEFF SMALL

12451 Starcrest Dr. #100

San Antonio, Texas 78216

jdslaw1951@gmail.com

Norman L. Nevins Via email/e-service

THE NEVINS LAW FIRM

206 West Main Street

Fredericksburg, Texas 78624

nnevinslaw@yahoo.com

/s/ Samuel V. Houston, III

SAMUEL V. HOUSTON, III