ACCEPTED 08-24-00357-CV 08-24-00357-CV EIGHTH COURT OF APPEALS EL PASO, TEXAS 11/5/2024 10:36 AM ELIZABETH G. FLORES CLERK No. 08-24-00357-CV FILED IN 8th COURT OF APPEALS EL PASO, TEXAS IN THE EIGHTH DISTRICT COURT OF APPEALS , 10:36:53 AM 11/5/2024 EL PASO, TEXAS ELIZABETH G. FLORES Clerk Michael Helling, Jackson Helling, and Courtney Trujillo, Appellants, v. Tanya Kerr and TDK Acquisitions, LLC d/b/a/ T. Kerr Property Group, Appellees. APPELLANTS’ UNOPPOSED EMERGENCY MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF TO THE HONORABLE COURT: Appellants Michael Helling, Jackson Helling, and Courtney Trujillo file this second Unopposed Motion for Extension of Time to file their opening brief, requesting a one-week extension, and in support state as follows. Appellants’ opening brief is due on November 5, 2024. That deadline was the byproduct of a two-week extension of the initial deadline based on the parties’ efforts to facilitate prospects for mediation. This is Appellants’ s second motion to extend the deadline. An emergency has occurred that renders it impossible for Appellants to file the brief of appellants by today’s deadline. Counsel for Appellees has graciously agreed that the circumstances warrant an extension and do not oppose this request. Counsel for Appellants thus make this unopposed request to extend the deadline for filing their opening brief until November 12, 2024. This motion is filed so that justice may be done. PRAYER FOR RELIEF Wherefore, premises considered, Appellants respectfully request that the deadline for filing their opening brief be extended until November 12, 2024. Respectfully submitted, /s/ Michael S. Truesdale BARRON & NEWBURGER, P.C. AMINI & CONANT, P.C. Michael S. Truesdale R. Alex Conant Texas State Bar No. 00791825 Texas State Bar No. 24074061 mtruesdale@bn-lawyers.com alex@aminiconant.com Francesca A. DiTroia Aaron T. Gankofskie Texas State Bar No. 24097596 aaron@aminiconant.com 7320 N. MoPac Expy. Texas State Bar No. 24101785 Greystone II, Suite 400 1204 San Antonio Street Austin, TX 78731 Second Floor 737-263-1241 Austin, TX 78701 512-279-0310 (fax) 512-222-6883 Counsel for Michael Helling and 512-990-7967 (fax) Jackson Helling Counsel for Courtney Trujillo 2 CERTIFICATE OF CONFERENCE The undersigned certifies that he conferred with Austin Jones, counsel for Appellees, regarding the merits of this motion, and Mr. Jones graciously confirmed that the relief requested in this motion is unopposed. /s/ Michael S. Truesdale Michael S. Truesdale CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of this motion was served on Austin Jones, counsel for Appellees, by e-filing on this fifth day of November, 2024. /s/ Michael S. Truesdale Michael S. Truesdale 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Michael Truesdale on behalf of Michael Truesdale Bar No. 791825 mtruesdale@bn-lawyers.com Envelope ID: 93939708 Filing Code Description: Motion Filing Description: Appellants' Motion for Extension of Time to file Brief of Appellants Status as of 11/5/2024 1:17 PM MST Associated Case Party: JacksonHelling Name BarNumber Email TimestampSubmitted Status Francesca A.Di Troia fditroia@bn-lawyers.com 11/5/2024 10:36:53 AM SENT Michael STruesdale mtruesdale@bn-lawyers.com 11/5/2024 10:36:53 AM SENT Associated Case Party: TanyaKerr Name BarNumber Email TimestampSubmitted Status Tanya Kerr ajones@mcginnislaw.com 11/5/2024 10:36:53 AM SENT Associated Case Party: TDK Acquisitions, LLC Name BarNumber Email TimestampSubmitted Status austin jones ajones@mcginnislaw.com 11/5/2024 10:36:53 AM SENT Associated Case Party: CourtneyTrujillo Name BarNumber Email TimestampSubmitted Status Roger Conant 24074061 alex@aminiconant.com 11/5/2024 10:36:53 AM SENT