Kyle Tauch, Tranquility Apartments General Corporation and Tranquility Apartments Ltd. v. Joel R. Scott ( 2015 )

ACCEPTED
14-14-00169-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
6/8/2015 11:01:06 AM
CHRISTOPHER PRINE
CLERK
No. 14-14-00169-CV
In the Court of Appeals for the FILED IN
14th COURT OF APPEALS
Fourteenth Court of Appeals District at Houston HOUSTON, TEXAS
6/8/2015 11:01:06 AM
CHRISTOPHER A. PRINE
Clerk
Kyle Tauch, Tranquility Apartments
General Corporation and
Tranquility Apartments, Ltd.,
Appellants/Cross-Appellees,
v.
Joel R. Scott,
Appellee/Cross-Appellant.
Appeal from the 80th Judicial District Court of Harris County, Texas
Trial Court Cause No. 2011-21305
Unopposed First Motion for Extension
of Time to File Reply Brief of Cross-Appellant
TO THE HONORABLE COURT OF APPEALS:
Appellee/Cross-Appellant, Joel R. Scott, respectfully files this Unopposed
First Motion for Extension of Time to File his Reply Brief of Cross-Appellant.
1. The present deadline for filing the reply brief is June 8, 2015.
2. Appellee/Cross-Appellant seeks a two-week extension, until June 22,
2015, in which to file his reply brief.
3. This is Appellee/Cross-Appellant’s first request for an extension of
time to file the brief.
4. This motion is unopposed.
5. Appellee/Cross-Appellant needs the additional time to file his brief
with this Court for the following reasons:
Lead appellate counsel, Chad Flores, has been engaged in other litigation
with imminent deadlines that have prevented him from completing the reply brief
before the deadline, including, but not limited to, the following:
 Assistance in preparation of a petitioners’ brief on the merits in No.
14-0507, Ineos USA, LLC v. Elmgren, in the Supreme Court of Texas.
The petitioners’ brief was filed May 22, 2015.
 Assistance in preparation of a petitioner’s brief on the merits in No.
14-0894, Meritage Homes of Texas, L.L.C. v. Ruan, in the Supreme
Court of Texas. The petitioner’s brief was filed on June 1, 2015.
 Preparation of a real party in interest’s brief on the merits in No.
14-0804, In re Seneca Resources Corp., in the Supreme Court of
Texas. The real party in interest’s brief on the merits is due to be filed
on or before June 22, 2015.
 Assistance in preparation of a reply brief in No. 14-20717, Forum
Subsea Rentals v. Elsharhawy, in the United States Court of Appeals
for the Fifth Circuit. The appellants’ reply is due to be filed on or
before June 22, 2015.
 Assistance in preparation of a petitioner’s reply in support of a
petition for review in No. 14-0971, Clef Construction, Inc. v. CCV
Holdings, LLC, in the Supreme Court of Texas. The petitioner’s reply
is due to be filed on or before June 22, 2015.
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 Preparation of a brief of appellee in No. 01-15-232-CV, Nationwide
Distribution Services, Inc. v. Jones, in the Court of Appeals for the
First District of Texas. The brief of appellee is due to be filed on or
before June 29, 2015.
 Preparation of responses to five motions for summary judgment in In
re West Explosion Cases (City of West v. CF Industries Sales, LLC),
in the 170th District Court of McLennan County. The responses are
due to be filed on or before July 8, 2015.
6. This motion is not filed for the purpose of delay, but to allow counsel
adequate time to prepare the cross-appellant’s reply brief.
PRAYER FOR RELIEF
For these reasons, Appellee/Cross-Appellant respectfully requests that this
Court grant him an extension of time to file his reply brief until June 22, 2015.
Respectfully submitted,
BECK REDDEN LLP
By: /s/ Chad Flores
Chad Flores
State Bar No. 24059759
1221 McKinney, Suite 4500
Houston, Texas 77010
713.951.3700
713.951.3720 (Fax)
cflores@beckredden.com
Attorneys for Appellee/Cross-Appellant,
Joel R. Scott
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Certificate of Conference
I certify that I conferred with appellate counsel for Appellant, who does not
oppose the requested extension.
/s/ Chad Flores
Chad Flores
Certificate of Service
A true and correct copy of the above and foregoing motion was properly
forwarded to counsel of record for Appellant in accordance with Texas Rules of
Appellate Procedure 9.5 by the e-file service provider on this the 8th day of June,
2015, addressed as follows:
Michele Barber Chimene
The Chimene Law Firm
15203 Newfield Bridge Lane
Sugar Land, TX 77498
michelec@airmail.net
Counsel for Appellants/Cross-Appellees Kyle Tauch, Tranquility Apartments
General Corporation and Tranquility Apartments, Ltd.
/s/ Chad Flores
Chad Flores
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