IN THE COURT OF APPEALS 

FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS 

AT HOUSTON 

No. 14-15-00123-CV

Kelvin Gold, 

Appellant 

v.

Helix Energy Solutions Group, Inc. and Helix Offshore International, Inc. 

Appellees 

On Appeal from the 270th District Court, Harris County, Texas 

Trial Court Cause No. 2013-59134 

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANT’S BRIEF 

Caj D. Boatright 

State Bar No. 24036237 

cboatright@arnolditkin.com

Kurt B. Arnold 

State Bar No. 24036150 

karnold@arnolditkin.com 

ARNOLD & ITKIN LLP

6009 Memorial Drive 

Houston, TX 77007 

Telephone: (713) 222-3800 

Facsimile: (713) 222-3850 

e-service@arnolditkin.com

COUNSEL FOR APPELLANT 

ACCEPTED

14-15-00123-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

7/20/2015 2:07:36 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/20/2015 2:07:36 PM CHRISTOPHER A. PRINE Clerk
TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Appellant Kelvin Gold (“Gold”), through undersigned counsel, respectfully 

moves this honorable Court for an extension of time in which to file Appellant’s 

brief in the above-captioned appeal, and as grounds states as follows:

1. The Clerk’s Record on Appeal in this cause was filed on March 23, 

2015 with the 14

th Court of Appeals. 

2. For the last few weeks, Counsel for Gold has been required to travel 

out-of-state on numerous occasions for hearings and depositions and will be 

traveling to Chicago, Illinois on the day the Gold’s brief is due. Due to counsel for 

Gold’s current workload, previously scheduled depositions, court appearances and 

trials in other matters, counsel for Gold needs more time to adequately review the 

record on appeal and prepare Appellant’s brief. 

3. Appellant’s brief is currently due July 21, 2015.

4. Appellant requests an extension of two (2) weeks, so that Appellant’s 

brief may be prepared. Such an extension would extend the filing date for 

Appellant’s brief to August 4, 2015.

5. This is Gold’s first request for an extension of time on his reply brief.

6. The undersigned has conferred with counsel for Appellee, who has no 

opposition to the relief requested, and was granted an extension of time to file its 

opening brief.
7. This extension request is not intended for any undue delay or 

prejudice, but so that Gold has sufficient time to prepare his brief and that justice 

may be done.

 WHEREFORE, Gold respectfully requests that this Honorable Court grant 

this motion, affording him a two (2) week extension of time, through and until 

August 4, 2015, to file his brief, and for such other and further relief as this 

Honorable Courts deems appropriate.

Respectfully submitted,

ARNOLD & ITKIN LLP

/s/ Caj D. Boatright

Caj D. Boatright

State Bar No. 24036237

cboatright@arnolditkin.com

Kurt B. Arnold

State Bar No. 24036150

karnold@arnolditkin.com

6009 Memorial Drive

Houston, TX 77007

Telephone: (713) 222-3800

Facsimile: (713) 222-3850

e-service@arnolditkin.com

COUNSEL FOR APPELLANT
CERTIFICATE OF CONFERENCE

Counsel for Appellant Kelvin Gold has conferred with counsel for Appellee

in a good faith effort to avoid any issues that might be raised by this motion. 

Counsel for Appellee has advised that he has no opposition to the extension of time 

requested herein.

/s/ Caj D. Boatright

Caj D. Boatright

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing 

Unopposed Motion for Extension of Time to File Appellant’s Brief has been 

forwarded to all counsel of record in accordance with the Texas Rules of Appellate 

Procedure on this 20th day of July, 2015.

Susan Noe Wilson

Bland & Partners, PLLC

1717 St. James Place, Suite 360

Houston, Texas 77056

Counsel for Appellees Helix Energy Solutions Group, Inc. and 

Helix Offshore International, Inc. 

/s/ Caj D. Boatright

Caj D. Boatright