No. 03-15-00368-CV

IN THE

THIRD COURT OF APPEALS

AUSTIN, TEXAS

_______________________________________

Laura Pressley,

 Appellant, 

 

v.

Gregorio “Greg” Casar,

 Appellee. 

_______________________________________

No. 03-15-00505-CV

David Rogers,

 Appellant, 

v.

Gregorio “Greg” Casar,

Appellee. 

_______________________________________

UNOPPOSED MOTION TO EXTEND TIME

TO FILE APPELLEE’S BRIEFS

_______________________________________

TO THE HONORABLE THIRD COURT OF APPEALS: 

On September 25, 2015, the Court granted Appellee Gregorio “Greg” Casar’s 

Unopposed Motion to Consolidate and Reset Briefing Deadlines. Accordingly, the 

deadlines in both of the above-styled appeals run from the filings in No. 03-15-00505-

CV. Appellant filed his brief in No. 03-15-505-CV on October 27, 2015, making 

ACCEPTED

03-15-00368-CV

7740700

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/9/2015 11:33:56 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/9/2015 11:33:56 AM JEFFREY D. KYLE Clerk
2

Appellee’s briefs for both appeals due on November 16, 2015. Pursuant to Rule 

10.5(b) and Rule 38.6 of the Texas Rules of Appellate Procedure, Appellee files this 

unopposed motion and asks for a thirty (30) day extension of time by which to file his 

briefs. Granting this motion would make the briefs due on December 16, 2015.

Appellee seeks this extension because his appellate counsel, Kurt Kuhn, has 

several other matters that have and continue to consume his docket, including:

• Preparing an amicus brief in No. 14-0743; Southwest Royalties, Inc. v. Hegar; 

Supreme Court of Texas;

• Preparing a Reply in Support of Petition for Review in No. 15-0504; 

Arbor Windsor Court, Ltd., v. Weekley Homes, L.P.; Supreme Court of 

Texas;

• Preparing an amicus brief in No. 15-0523; ACE Cash Express, Inc. v. The 

City of Denton, Texas; in the Texas Supreme Court; and

• Preparing a petition for review in No. 15-0725, Debra Hren v. Recruiting 

Partners GP, Inc. d/b/a Kinney Recruiting, Inc., due on December 4, 2015.

This request is not made for the purpose of delay. It is necessary to allow 

Appellee’s counsel time to properly prepare the briefs. This motion is the first 

extension requested in this matter, and counsel for Appellants does not oppose the 

relief sought. 

Prayer

For these reasons, Appellee asks for an additional thirty (30) days to file his 

briefs, extending the time until December 16, 2015.
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Dated: November 9, 2015 Respectfully submitted,

By:/s/Kurt Kuhn

Charles Herring, Jr.

State Bar No. 09534100

cherring@herring-irwin.com 

Lauren Ross

State Bar No. 24092001

laurenbross@herring-irwin.com

HERRING & PANZER, L.L.P.

1411 West Avenue, Suite 100

Austin, Texas 78701

(512) 320-0665

(512) 519-7580 (fax)

Kurt Kuhn

State Bar No. 24002433

kurt@kuhnhobbs.com

Lisa Bowlin Hobbs

State Bar No. 24026905

lisa@kuhnhobbs.com

KUHN HOBBS PLLC

3307 Northland Drive, Suite 310

Austin, Texas 78731-4946

(512) 476-6000

(512) 476-6002 (fax)

Jessica Palvino

State Bar No. 24048780

jpalvino@mcginnislaw.com

MCGINNIS, LOCHRIDGE & KILGORE, LLP

600 Congress Avenue, Suite 2100

Austin, Texas 78701

(512) 495-6079

(512) 505-6379 (fax)

Counsel for Appellee
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CERTIFICATE OF CONFERENCE

Pursuant to Texas Rule of Appellate Procedure 10.1, I hereby certify that I 

conferred with Appellant David Rogers and counsel for Laura Pressley, Mark Cohen, 

regarding this motion. Both Mr. Rogers and Mr. Cohen indicated that they are 

unopposed to the extension of time. 

/s/ Kurt Kuhn

Kurt Kuhn

CERTIFICATE OF SERVICE

I hereby certify that, November 9, 2015, I served electronically a copy of this 

motion on counsel of record as listed below:

Mark Cohen

805 West 10th Street, Suite 100

Austin, Texas 78701

mark@cohenlegalservices.com

David Rogers

Law Office of David Rogers

1201 Spyglass Suite 100

Austin, TX 78746

Firm@DARogerslaw.com

/s/ Kurt Kuhn

Kurt Kuhn