NOS. 01-13-00267-CV

01-13-00233-CV

IN THE COURT OF APPEALS

FOR THE FIRST DISTRICT OF TEXAS, 

HOUSTON, TEXAS

JAY H. COHEN, INDIVIDUALLY AND AS TRUSTEE OF THE JHC 

TRUSTS I AND II, Appellant

V.

SANDCASTLE HOMES, INC., Appellee

* * * * * * * * * * * * * * * *

JAY H. COHEN, INDIVIDUALLY AND AS TRUSTEE OF THE JHC 

TRUST I AND II, Appellant

V.

NEWBISS PROPERTY, LP, Appellee

On Appeal from the 234th District Court

Harris County, Texas

Trial Court Case Nos. 2010-20973A & 2010-20973B

APPELLEES’ UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE 

RESPONSE TO APPELLANT’S MOTION FOR REHEARING

TO THE HONORABLE COURT:

Pursuant to Texas Rules of Appellate Procedure 10.5(b and 49.8, Appellees 

Sandcastle Homes, Inc. (“Sandcastle”), and NewBiss Property, L.P. (“NewBiss”) 

ACCEPTED

01-13-00233-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

5/8/2015 10:40:58 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 5/8/2015 10:40:58 AM CHRISTOPHER A. PRINE Clerk
respectfully move the Court to extend the deadline to file Appellees’ response to 

Appellant's Motion for Rehearing. In support of this motion, Appellees show the 

Court as follows:

1. The deadline to file Appellees’ Response to Appellant’s Motion for 

Rehearing is May 20, 2015.

2. Appellees seek an extension of 15 days.

3. The extension is sought to compensate for scheduling conflicts of 

Appellees’ counsel. Blaine Hummel is getting married on May 16, 2015 and 

preparing for his wedding. Mr. Hummel is also scheduled to attend a court ordered 

mediation on May 20, 2015, in Adversary No. 14-0328, Knorvek, LLC, v. 

Unlimited Restoration Specialists, Inc., in the United States Bankruptcy Court for 

the Southern District of Texas. He is also set for trial on May 22, 2015 in 

Adversary No. 13-03315, Aleta Renee Chapman v. Green Tree Servicing, et al., 

also in the United States Bankruptcy Court for the Southern District of Texas. 

Additionally, Brad Irelan will be attending the graduation of his daughter in 

Virginia from May 15-18, 2015.

4. This is the first extension requested and is not sought for the purposes 

of delay.

5. Appellants are unopposed to this motion.
For these reasons, Appellees pray that this Court grant an extension of time

to file their Response to Appellant’s Motion in this matter through and including 

June 4, 2015.

IRELAN MCDANIEL, PLLC

 /s/ Blaine Hummel

Bradford W. Irelan

birelan@IMTexaslaw.com

State Bar No. 10411550

Blaine Hummel

bhummel@IMTexaslaw.com

State Bar No. 24012872

440 Louisiana Street, Suite 1800

Houston, Texas 77002-1652

Telephone: (713) 222-7666

Facsimile: (713) 222-7669

ATTORNEY FOR APPELLEES

SANDCASTLE HOMES, INC., 

AND NEWBISS PROPERTY, L.P 

CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with counsel for Appellants who stated that 

they are not opposed to the relief sought herein.

 /s/ Blaine Hummel

Blaine Hummel
CERTIFICATE OF SERVICE

The undersigned hereby certifies that on May 8, 2015, a true and correct 

copy of Appellees’ Unopposed Motion to Extend Time has been served by 

electronic service on the below-listed counsel in compliance with the Texas Rules 

of Appellate Procedure.

Kemp W. Gorthey

604 West 12th Street

Austin, Texas 78701

(512) 479-6417 Facsimile

James Eloi Doyle

Nicole S. Bakare

DOYLE, RESTREPO, HARVIN & ROBBINS, L.L.P.

600 Travis Street, Suite 4700

Houston, Texas 77002-3005 

(713) 228-6138 Facsimile

 /s/ Blaine Hummel

Blaine Hummel