No. 01-15-00067-CV 

IN THE COURT OF APPEALS 

FOR THE FIRST DISTRICT OF TEXAS 

HOUSTON, TEXAS 

RESIDENTIAL CREDIT SOLUTIONS, INC., 

Appellant, 

v. 

MARTHA BURG, 

Appellee. 

Appealed from the 281 st Judicial District Court 

of Harris County, Texas 

Trial Court Cause No. 2013-47157 

APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF 

Nathan J. Milliron 

State Bar No. 24030984 

HUGHES WATTERS ASKANASE, L.L.P. 

Three Allen Center 

3 3 3 Clay, 29th Floor 

Houston, Texas 77002 

(713) 759-0818 (Telephone) 

(713) 759-6834 (Facsimile) 

nmilliron@hwa.com (Email) 

ATTORNEY FOR APPELLANT 

2913691: 1-F ARDCL-0005 

ACCEPTED

01-15-00067-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/15/2015 2:42:27 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/15/2015 2:42:27 PM CHRISTOPHER A. PRINE Clerk
Appellant, Residential Credit Solutions, Inc., asks the court to extend the 

time to file its brief. 

A. Introduction and Background Facts 

1. Appellant is Residential Credit Solutions, Inc. Appellee is Martha Burg. 

2. The undersigned is attorney-of-record for Appellant Residential Credit 

Solutions, Inc. 

3. The deadline to file Appellant's Brief is April17, 2015. 

4. Appellant requests a 14-day extension of time to file its Brief. 

B. Argument & Authorities 

5. Rule 1 0.5(b) authorizes Appellant to request an extension of time to file 

its Brief. 

6. The deadline for filing Appellant's Brief is currently April 17, 2015. 

7. This is the fist request for an extension of time to file Appellant's Brief. 

8. Counsel for Appellant has been assigned and called to trial three times in 

the last month and additional time is needed to finalize Appellant's Brief. 

Appellant has been in trial in the following cases: 

(a) Cause No. 13-CV-1509 styled Joel Just v. David J. Brown, in the 

405th Judicial District Court of Galveston County, Texas [bench 

trial on March 25, 2015]; 

(b)Cause No. 11-DCV-194122 styled AJBJK. L.L.P. v. Saefaldin 

Rahmati and Abdul Saeed Assadi Rahmati, in the 240th Judicial 

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District Court of Fort Bend County, Texas [bench trial on April 1, 

2015]; and 

(c)Cause No. 65341 styled FV-1. Inc. in Trust for Morgan Stanley 

Capital Holdings LLC v. Sandra Jeter and Thomas Jeter, in the 

149th Judicial District Court of Brazoria County, Texas Oury trial 

starting on April 6, 20 15). 

9. In addition, counsel for Appellant was scheduled for jury trial on March 

23, 2015 in Cause No. 2011-60277-393 styled Kenneth Fong and Pamela Fong v. 

Nationstar Mortgage. LLC and Federal National Mortgage Association, in the 

393rd Judicial District Court of Denton County, Texas and was not released until 

the late afternoon of March 20, 2015. 

10. The length of the extension sought is 14-days from the April 17, 2015 

due date. 

11. The Court has authority to extend the time to file the Appellant's Brief 

under TEx. R. APP. P. 38.6(d). 

12. Appellant requests a 14-day extension of time to file its Brief. 

C. Conclusion 

13. The undersigned, as attorney for Residential Credit Solutions, Inc., 

requests an extension of 14 days to file Appellant's Brief. 

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D. Prayer 

14. Residential Credit Solutions, Inc. asks the Court to grant this motion and 

extend the time for filing its Appellant's Brief for 14 days. 

Respectfully submitted, 

HUGHES WATTERS ASKANASE, LLP 

By: =lliron , ---------.._ 

State Bar No. 24030984 

Three Allen Center 

333 Clay, 29th Floor 

Houston, Texas 77002 

(713) 759-0818 (Telephone) 

(713) 759-6834 (Facsimile) 

nmilliron@hwa.com (E-mail) 

ATTORNEY FOR APPELLANT 

CERTIFICATE OF CONFERENCE 

I, the undersigned attorney, hereby certify that Mr. O'Connor, counsel for 

Martha Burg, is opposed to this extension of time to file Appellant's Brief. 

N~~ 

291369 1: 1-F ARDCL-0005 
CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the foregoing Appellant's 

Motion for Extension of Time to File Brief was served upon all parties and/or their 

attorneys of record, in accordance with the Texas Rules of Civil Procedure, on this 

the 15th day of April2015, addressed as follows: 

Via Electronic Mail at moconnor@oconnorcraig.com 

Mr. Michael C. O'Connor 

O'Connor, Craig, Gould, Evans & Rohr 

2500 Tanglewilde, Suite 222 

Houston, Texas 77063 

2913691: 1-F ARDCL-0005