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:

Pur su ant to Texas Ru les of Appellate Procedu re 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

CLERKrespectf u lly move the Court to extend the deadline to file Appellees’ response to

App e llant ' s Motion for R ehearing

. In support of this motion, Appellees show the

Court as follows:

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

Rehear ing 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 schedule d 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 Dis t rict of Texas. He is also set for trial on May 22, 2015 i n

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 1 5

- 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 t h ese r easons, Ap pellees pray that t h is Court grant an e x ten s ion of time

to file their Response to Appellant’s Motio n in this matter th r ough and inc l ud i ng

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 APPELLEE S

SANDCASTLE HOMES, INC.,

AND NEWBISS PROPERTY, L.P

CERTIF I CATE OF CONFERENCE

I hereby certify that I conferred with coun s el for Appellants who stated that

they are not o p posed to the relief sought herein.

/s/ Blaine Hummel

Blaine HummelCERTIF I CATE OF SERVICE

The undersi gn e d hereby certifies that on May 8

, 2015, a true and correct

copy of Appell ee s ’ Unopposed Motion to Ext e nd Time has been served by

electronic service on the below

- listed counsel in compliance with the Texas R u les

of Appellate Procedure.

Ke m p W. Gorthey

6 04 West 12th S t reet

Austin, Texas 78701

(512) 479

- 6417 Facs im ile

Ja me s Eloi Doyle

N icol e S

. B a kare

D OYL E

, R ESTREPO

, H A R VIN & R O B BIN S

, L.L.P.

600 Travis Street, Suite 4700

Houston, Texas 77002

- 3005

(71 3) 228

- 6138 Facs im ile

/s/ Blaine Hummel

Blaine Hummel