Case Information
*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 2/26/2015 3:27:42 PM LISA MATZ Clerk *1 ACCEPTED 05-14-01415-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 2/26/2015 3:27:42 PM LISA MATZ CLERK NO. 05-14-01415-CV IN THE FIFTH COURT OF APPEALS DALLAS, TEXAS SOUTHAMPTON LTD. and SOUTHWEST REINSURANCE, INC.
Appellants, vs.
FOUR HORSEMEN AUTO GROUP, INC., CHISHOLM TRAIL AUTO
GROUP, LLC, CHISHOLM TRAIL AUTO GROUP II, LLC,
CHISHOLM TRAIL REAL ESTATE, LLC Appellees.
ON APPEAL FROM THE 101st DISTRICT COURT OF DALLAS COUNTY, TEXAS, NO. DC-13-13331 APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE REPLY IN SUPPORT OF APPEAL Werner A. Powers State Bar No. 16218800 State Bar No. 24077481 H AYNES AND B OONE , LLP 2323 Victory Avenue, Suite 700 Dallas, Texas 75219 214-651-5000 214-651-5940 (facsimile) ATTORNEYS FOR APPELLANTS *2
To the Honorable Fifth Court of Appeals:
Pursuant to Texas Rule of Appellate Procedure 10.5(b), Appellants file
this Unopposed Motion for Extension of Time in Which to File a Reply in
Support of their Appeal and hereby request the Court extend the deadline by
which to file a reply in support of their appeal by two (2) weeks, or until March
17, 2015. In support of their Motion, Appellants would show the Court the
following:
1. Appellants’ Reply is currently due on Tuesday, March 3, 2015.
2. No previous motions for extensions have been made.
3. Appellants seek an extension so that it may adequately address
Appellees’ evidentiary and substantive arguments, the response to which
requires detailed research and briefing. Counsel is in the process of preparing
the Reply, but in the interest of completing it correctly and thoroughly,
Appellants seek an additional two seeks in which to respond.
4. Appellees have no objection to this extension.
IV. P RAYER For these reasons, Appellants respectfully request that the Court extend
the deadline by which Appellants must file their reply in support of their appeal
for two (2) weeks, or until March 17, 2015.
*3 Respectfully submitted, HAYNES AND BOONE, LLP /s/ Werner A. Powers Werner A. Powers State Bar No. 16218800 State Bar No. 24077481 2323 Victory Avenue, Suite 700 Dallas, Texas 75219 Telephone: (214) 651-5000 Telecopier: (214) 651-5940 werner.powers@haynesboone.com natalie.dubose@haynesboone.com ATTORNEYS FOR APPELLANTS SOUTHAMPTON, LTD. AND SOUTHWEST REINSURANCE, INC.
CERTIFICATE OF SERVICE This certifies that a true and correct copy of the foregoing instrument has
been sent to all counsel of record to the appeal in accordance with the Texas
Rules of Civil Procedure on this 26th day of February, 2015.
James J. Doyle III
The Doyle Law Firm
4054 McKinney Ave., Suite 310
Dallas, Texas 75204
james@doylelawonline.com
Additionally, a courtesy copy has been provided to the following
attorneys:
Mark A. Shank Leonard (Ladd) A. Hirsch
Gruber Hurst Johansen Hail Shank James D. Sheppard
1445 Ross Avenue, Suite 2500 Diamond McCarthy, LLP
Dallas, Texas 75202-2711 1201 Elm Street Suit, 3400
mshank@ghjhlaw.com Dallas, Texas 75209
LHirsch@diamondmccarthy.com /s/ Natalie DuBose 15048542_1