No. 01-15-00067-CV INTHE COURT OF APPEALS FORTHE FIRSTDISTRICT OF TEXAS HOUSTON, TEXAS
RESIDENTIAL CREDIT SOLUTIONS, INC., Appellant, 

## v. MARTHA BURG, Appellee. Appealed from the 281 st Judicial DistrictCourt ofHarris County, Texas Trial Court Cause No. 2013-47157
APPELLANT'S MOTIONFOREXTENSION OF TIME TOFILE BRIEF

NathanJ. Milliron State BarNo. 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 FORAPPELLANT

2913691: 1-FARDCL-0005 ACCEPTED 01-15-00067-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/15/2015 2:42:27 PM CHRISTOPHER PRINE

CLERKAppellant, 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 MarthaBurg. 2. The undersigned is attorney-of-record for Appellant Residential Credit Solutions, Inc. 3. The deadline to file Appellant's Briefis April17, 2015. 4. Appellant requests a 14-day extension oftime to file its Brief. 

### B. Argument & 

### Authorities 5. Rule 1 0.5(b) authorizes Appellant to request an extension oftime to file its Brief. 6. The deadline for filing Appellant's Briefis currently April 17, 2015. 7. This is the fist request for an extension oftime to file Appellant'sBrief. 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. 

### DavidJ. 

### 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
2913691: 1-F ARDCL-0005District Court ofFort 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 ofBrazoria County, Texas 

## Oury trial starting on April 6, 2015). 9. In addition, counsel for Appellant was scheduled forjury trial on March 23, 2015 in Cause No. 2011-60277-393 styled 

### Kenneth Fong andPamela Fong v. Nationstar Mortgage. LLC and Federal National Mortgage Association, in the 393rd Judicial District Court ofDenton County, Texas and was not released until the late afternoon ofMarch 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 oftime 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.

2913691:1-FARDCL-0005D. Prayer 14. Residential Credit Solutions, Inc. asks the Court to grant this motion and extendthe time for filing its Appellant's Brieffor 14 days. Respectfully submitted, HUGHES WATTERS ASKANASE, LLP By:

# =lliron , ---------.._ State BarNo. 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 FORAPPELLANT CERTIFICATE OF CONFERENCE I, the undersigned attorney, hereby certify that Mr. O'Connor, counsel for MarthaBurg, is opposed to this extension oftime 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 ofTime to File Briefwas served upon all parties and/or their attorneys ofrecord, in accordance with the Texas Rules ofCivil Procedure, on this the 15th day ofApril2015, addressed as follows: Via ElectronicMail atmoconnor@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