Kelvin Gold v. Helix Energy Solutions Group, Inc. ( 2015 )

ACCEPTED 14-15-00123-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/20/2015 2:07:36 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS AT HOUSTON FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/20/2015 2:07:36 PM No. 14-15-00123-CV CHRISTOPHER A. PRINE Clerk 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 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 14th 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