APPELLANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLANTS' BRIEF – Page 1 5797875 v1 (70638.00002.000)

No. 03-17-00771-CV 

_______________________________________________________________

THIRD COURT OF APPEALS 

AUSTIN, TEXAS

_______________________________________________________________

Texas Jewelers Association, Rex Solomon, and Brad Koen,

 Appellants

v.

Ann Glynn, 

 Appellee

__________________________________________________________________

Appeal from the 98th Judicial District Court, Travis County, Texas, 

Cause No. D-1-GN-17-005031

___________________________________________________________________

APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO 

FILE APPELLANTS’ BRIEF

___________________________________________________________________

TO THE HONORABLE THIRD COURT OF APPEALS:

Appellants Texas Jewelers Association, Rex Solomon and Brad Koen, 

pursuant to Tex. R. App. P. 38.6(d), respectfully file this Motion for Extension of 

Time to File Brief, requesting additional time to file their Appellants’ Brief, and in 

support would show the following:

1. Appellants’ brief is due on December 20, 2017. Tex. R. App. P. 

10.5(b)(1)(A). Appellants seek an extension of 30 days from that date to January 

19, 2018. Tex. R. App. P. 10.5(b)(1)(B).

ACCEPTED

03-17-00771-CV

21107254

THIRD COURT OF APPEALS

AUSTIN, TEXAS

12/6/2017 8:43 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/6/2017 8:43:46 AM JEFFREY D. KYLE Clerk
APPELLANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLANTS' BRIEF – Page 2 5797875 v1 (70638.00002.000)

2. Pursuant to Tex. R. App. P. 10.5(b)(1)(C), this extension of time to 

file Appellants’ brief is requested because the undersigned counsel for all three

Appellants, Michael A. Logan and Kenneth C. Riney, began a jury trial on 

December 5, 2017, that is expected to take two to three weeks to complete. The 

case is styled David Bagwell, Individually and as Trustee of the David S. Bagwell 

Trust; Broughton Limited Partnership; Old Grove Limited Partnership; Broadland 

Limited Partnership; Marilyn D. Garner, Chapter 7 Trustee of the Estate of the 

David Bagwell Company and Trustee of the Estate of Evermore Communities, Ltd. 

v. BBVA Compass and Sam Meade, Cause No. DC-14-00991 in the 101st Judicial 

District Court of Dallas County, Texas. 

3. Given this trial setting and the Christmas holiday the following week, 

Movants request this extension of time to adequately prepare Appellants’ brief, 

including coordinating preparation of an anticipated combined brief with cocounsel for Appellant Rex Solomon, Chamberlain McHaney. 

4. No previous extensions have been requested or granted related to an 

extension of time to file Appellants’ brief. Tex. R. App. P. 10.5(b)(1)(D).

5. This request is not for delay only, but that justice may be done. 
APPELLANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

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6. The undersigned attorney for Appellants has conferred with counsel 

for Appellee, Dennis Richard, and he does not oppose this requested extension. 

Tex. R. App. P. 10.1(a)(5). Appellants are agreeable to a similar extension for 

Appellee's brief. 

WHEREFORE, Appellants Texas Jewelers Association, Rex Solomon and 

Brad Koen respectfully request the Court to grant this Appellants’ Unopposed 

Motion for Extension of Time to File Appellants’ Brief.

Respectfully submitted, 

KANE RUSSELL COLEMAN LOGAN PC

By: /s/ Kenneth C. Riney

Michael A. Logan

State Bar No. 12497500

E-mail: mlogan@krcl.com

Kenneth C. Riney

State Bar No. 24046721

E-mail: kriney@krcl.com

3700 Thanksgiving Tower

1601 Elm Street

Dallas, Texas 75201

Telephone: (214) 777-4200

Facsimile: (214) 777-4299

ATTORNEYS FOR APPELLANTS

TEXAS JEWELERS ASSOCIATION,

REX SOLOMON AND BRAD KOEN
APPELLANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLANTS' BRIEF – Page 4 5797875 v1 (70638.00002.000)

Tim Poteet

tpoteet@chmc-law.com

State Bar No. 16170300

J. Gordon McHaney

gmchaney@chmc-law.com

State Bar No. 13670100

CHAMBERLAIN ♦ MCHANEY

301 Congress, 21st Floor

Austin, Texas 78701

ATTORNEYS FOR APPELLANT

REX SOLOMON

CERTIFICATE OF CONFERENCE

The undersigned hereby certifies he has conferred with counsel for Appellee 

Ann Glynn, Dennis L. Richard, regarding the relief requested in this Appellants’ 

Motion for Extension of Time to File Appellants’ Brief, and he is unopposed. Tex. 

R. App. P. 10.1(a)(5).

/s/ Kenneth C. Riney

Kenneth C. Riney
APPELLANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLANTS' BRIEF – Page 5 5797875 v1 (70638.00002.000)

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of foregoing 

has been served upon counsel of record by electronic court filing and/or electronic 

mail on this 6th day of December 2017.

DENNIS.RICHARD@KENNARDLAW.COM

Dennis L. Richard

State Bar No. 16842600

Kennard Richard PC

100 N.E. Loop 410, Suite 610

San Antonio, TX 78216

(210) 314-5688

(210) 314-5687 facsimile

Attorney for Appellee Ann Glynn

/s/ Kenneth C. Riney

Kenneth C. Riney