Pursuant to Texas Rules of Appellate Procedure 38.6(d) and 10.5(b), Appellants Gramercy Advisors LLC, Gramercy Asset Management, LLC,

Gramercy Local Markets Recovery Fund LLC and Gramercy Financial Services,

LLC (collectively, "Gramercy") submit this unopposed motion to extend the time

for filing their appellate brief in this matter.

1. The deadline for Gramercy to file its brief is currently January 21, 2015.

2. Gramercy respectfully requests a 12-day extension of time, until February 2,2015, to file its appellate brief.

3. Gramercy requests this second extension because the parties have not yet been able to obtain a copy of the Clerk's Record or the Reporter's Record

(collectively, the "Record"). The Record was filed in this Court under seal to the so" District Court's Sealing Order dated June 20, 2014.

pursuant

Gramercy's request for a copy of the Record was denied because no Order or other

similar instrument authorizes release of the Record to any of the parties. The

parties need a copy of the Record so they can properly prepare citations in their

respective appellate briefs. To obtain a copy, the parties have filed an agreed

request on January 15, 2015, in the so" District Court for entry of an order

granting the parties access to these documents. Once that order is signed, the

parties will then file an agreed request with the Harris County District Clerk asking

him to supplement the Record with the order authorizing the parties to obtain a

copy of the Record. A second extension of time is necessary to ensure this

process's timely completion and so Gramercy may properly prepare its citations.

4. Gramercy has requested only one time extension in this matter, which this Court granted. This extension is not sought for the purpose of delay, but so

that Gramercy can thoroughly brief the issues before the Court.

5. Appellees' counsel does not object to the relief sought herein. FOR THE FOREGOING REASONS, Gramercy respectfully requests that this Court grant a 12-day extension of time, extending Gramercy's deadline until

February 2, 2015, or, alternatively, grant such other and further relief as it shall

deem just and proper.

Respectfully submitted, By: David C. Mattka *4 David C. Mattka (TSB No. 13231500)

MUNSCH HARDT KOPF & HARR, P.C.

401 Congress Avenue, Suite 3050

Austin, Texas 78701

(512) 391-6100 (telephone)

(512) 391-6149 (facsimile)

E-mail: dmattka@munsch.com

Daniel M. Hibshoosh (pro hac vice, pending)

O'SHEA PARTNERS LLP

521 Fifth Avenue

25th Floor

New York, New York 10175

Tel: (212) 682-4426

Fax: (212) 682-4437

E-mail: dhibshoosh@osheapartners.com

MHDocs 5901773_1 \0862.1

CERTIFICATE OF CONFERENCE I certify that I conferred via e-mail correspondence with W. Ralph Canada, Jr., lead counsel for Appellees, on January 14th and 15th of 2015 and that

Appellees do not oppose this Second Unopposed Motion to Extend Time to File

Appellants' Brief.

CERTIFICATE OF SERVICE As required by Texas rule of Appellate Procedure 6.3 and 9.5, I hereby certify that on January 15, 2015, I served this document via e-filing and e-mail on

the following:

W. Ralph Canada, Jr.

ralphc@lfdlaw.com

David R. Deary

davidd@lfdlaw.com

Wilson Wray

wilsonw@lfdlaw.com

Tyler Simpson

tylers@lfdlaw.com

Loewinsohn Flegel Deary, LLP

12377 Merit Drive, Suite 900

Dallas, Texas 75251 A--c-------

Attorneys for Appellees "'. David C. Mattka