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NO. 03-14-00714-CV 

IN THE COURT OF APPEALS 

THIRD JUDICIAL DISTRICT OF TEXAS 

AUSTIN, TEXAS

On Appeal from the 98th Judicial District Court of Travis County 

Cause Number No. D-1-GN-12-002467 

KEVIN TARR 

Appellant, 

v. 

LANTANA SOUTHWEST HOMEOWNERS’ ASSOCIATION, INC., 

Appellee, 

AGREED MOTION TO EXTEND TIME 

TO THE HONORABLE COURT: 

 Appellee, Lantana Southwest Homeowners’ Association (“Lantana”) 

files this First Unopposed Motion for Extension of Time to File Appellee’s Reply 

Brief, pursuant to Texas Rules of Appellate Procedure 38.6 and 10.5(b)(1), and 

would respectfully show unto the Court the following: 

1. The current deadline for filing Lantana’s Reply Brief is April 16, 

2015. 

2. Lantana seeks a 30-day extension of time to file its Reply Brief, 

whereby the deadline would be on May 16, 2015. 

ACCEPTED

03-14-00714-CV

4685527

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/30/2015 9:30:05 AM

JEFFREY D. KYLE

CLERK

ACCEPTED

03-14-00714-CV

4715673

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/31/2015 3:54:16 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/31/2015 3:54:16 PM JEFFREY D. KYLE Clerk
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 3. This extension of time is sought because the briefing required for the 

Reply Brief is extensive, and the undersigned counsel for Lantana has both 

depositions and a mediation in two multiple party cases during the time the 

briefing is required under the current deadline. Because the cases both involve 

multiple parties and because the dates were agreed upon in advance of Appellant’s 

Brief, it would be inefficient and impractical to attempt to reschedule the prior 

commitments so that adequate time may be afforded to the briefing. 

4. This is the first Motion for Extension of Time filed with the court by 

Lantana. 

5. This motion is agreed/unopposed. 

6. This extension of time is not requested for mere delay, but to allow 

counsel adequate time to accurately present the issues on appeal. 

 For these reasons, Appellee Lantana respectfully requests that this Court 

grant a 30-day extension of time to file its Reply Brief herein, and set the deadline 

for filing the same to May 16, 2015. 
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Respectfully submitted, 

ROBERTS MARKEL WEINBERG BUTLER HAILEY PC 

___________________________________ 

GREGORY B. GODKIN 

Texas State Bar No. 24002146 

111 Congress, Suite 1620 

Austin, TX 78701 

ggodkin@rmwbhlaw.com 

Telephone: (512) 279-7344 

Fax: (713) 840-9404 

Attorneys for Lantana Southwest Homeowners’ 

Association, Inc.

CERTIFICATE OF COMPLIANCE

Pursuant to Rule 9.4 i(3) of the Texas Rules of Appellate Procedure, I certify 

that the word count in this Lantana Southwest Homeowners’ Association, Inc.’s 

First Unopposed Motion for Extension of Time to File its Appellee Brief is 523 

words. 

_________________________________ 

 GREGORY B. GODKIN

CERTIFICATE OF CONFERENCE

On March 26, 2014, Gregory B. Godkin, counsel for Appellee, conferred 

with Matthew Ploeger, counsel for Appellant, regarding the matter at issue in this 

Motion. Mr. Ploeger is agreed/unopposed to the relief sought in Lantana 
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Southwest Homeowners’ Association, Inc.’s First Motion for Extension of Time to 

File its Reply Brief. 

 

 _________________________________ 

 GREGORY B. GODKIN

CERTIFICATE OF SERVICE

I hereby certify that pursuant to Tex. R. Civ. P. 21a, a true and correct copy 

of the foregoing instrument was served upon the parties listed below by fax, 

delivery service, messenger, mail, and/or through the serving party’s electronic 

filing service provider, this 30th day of March, 2015. 

Via Facsimile No. (512) 298-1787

Mr. Matthew Ploeger 

Law Office of Matthew Ploeger 

901 S. Mopac Expressway, Suite 300 

Barton Oaks Plaza, Building One 

Austin, Texas 78746 

(512) 298-2088 Phone 

Attorney for Kevin Tarr 

 

 _________________________________ 

 GREGORY B. GODKIN