IN THE COURT OF APPEALS

FOR THE FIRST APPELLATE DISTRICT

NO. 01-15-00390-CV

JOHN T. PRESTON and C CHANGE INVESTMENTS, LLC

Appellants

v.

EMJO INVESTMENTS, LTD. and H.J. VON DER GOLTZ

Appellees

APPELLEES’ THIRD UNOPPOSED MOTION

FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEFS

Appellees Emjo Investments, Ltd. and H.J. von der Goltz file this Third 

Unopposed Motion for Extension of Time to File Appellees’ Briefs under the 

authority of Texas Rule of Appellate Procedure 10.5(b) and would respectfully 

show the following:

1. This is an accelerated appeal from an order of the 215th Judicial 

District Court entered November 17, 2014, denying the Special Appearances of 

John T. Preston and C Change Investments, LLC.

2. Preston and C Change filed separate opening briefs on June 12, 2015.

3. Appellees’ responsive briefs are due to be filed on or before July 27, 

2015.

4. This motion seeks an extension of time of 4 days, up to and including 

July 31, 2015, to file Appellees’ responsive briefs.

5. This is Appellees’ third request for an extension to file their briefs. On 

ACCEPTED

01-15-00390-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/23/2015 12:49:21 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/23/2015 12:49:21 PM CHRISTOPHER A. PRINE Clerk
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July 20, 2015, the Court granted Appellees’ second request for an extension, 

setting the deadline to file as July 27, 2015. The court’s order stated that no further 

extensions would be granted absent exceptional circumstances.

6. Counsel for Appellees has been ill with a stomach virus since July 20, 

2015, and has been unable to work on the briefs due herein as well as other matters 

since that time and continues to be unable to work on same due to her health.

7. Counsel for Appellees believes that the four-day extension requested 

herein will not interfere with the trial of this matter, currently set for May 2016.

Wherefore Appellees Emjo Investments, Ltd. and H.J. von der Goltz 

respectfully request that the Court find that exceptional circumstances exist for a 

further extension and extend the time for them to file their responsive briefs by 4

days, up to and including July 31, 2015.

Respectfully submitted, 

ELLISON & KELLER, P.C.

/s/Kelley M. Keller

By: Kelley M. Keller

State Bar No. 11198240

5120 Woodway, Suite 6019 

Houston, Texas 77056

Telephone: 713-266-8200 

Facsimile: 713-266-8201 

kkeller@ellison-keller.com

Attorneys for Appellees
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CERTIFICATE OF CONFERENCE

I, Kelley M. Keller, certify that on July 23, 2015, I conferred with counsel 

for the Appellants regarding the briefing schedule in this appeal. Counsel for 

Appellants does not oppose the relief sought in this motion.

/s/Kelley M, Keller

Kelley M. Keller

CERTIFICATE OF SERVICE

A true and correct copy of this Appellees’ Third Unopposed Motion for 

Extension of Time to File Appellees’ Briefs has been forwarded to all counsel of 

record on July 20, 2015, via email and/or eservice as follows:

Asher Griffin

Chris Sileo

Sean Flammer

SCOTT, DOUGLASS & MCCONNICO, LLP

600 Congress Ave., Ste 1500

Austin, Texas 78701-2589

Facsimile: 512-474-0731

agriffin@scottdoug.com

Attorneys for Defendants 

Chalsys Capital Partners, Meliora Energy 

Technologies, S.a.r.L, and Sonia Lo

Jane Langdell Robinson

Jamie Aycock

AHMAD. ZAVITSANOS, ANAIPAKOS, ALAVI &

 MENSING P.C.

3460 One Houston Center

1221 McKinney Street

Houston. Texas 77010

Facsimile: 713-658-0062

sgorman@azalaw.com

jrobinson@azalaw.com

jamieaycock@azalaw.com

Attorneys for Appellant Christoph Henkel

F. Eric Fryar

Matthew Buschi

Christina Richardson

FRYAR LAW FIRM, P.C.

912 Prairie, Suite 100

Houston, Texas 77002-3145

Facsimile: 281-605-1888

eric@fryarlawfirm.com

Attorneys for all Intervenors/Plaintiffs

/s/Kelley M. Keller

Kelley M. Keller