Case Information

*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 5/18/2015 10:26:54 AM LISA MATZ Clerk *1 ACCEPTED 05-14-00874-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 5/18/2015 10:26:54 AM LISA MATZ CLERK NO. 05-14-00874-CV IN THE COURT OF APPEALS FOR THE FIFTH DISTRICT OF TEXAS AT DALLAS HASSAN PARSA, Appellant, v.

VINCENT WALKER, Appellee.

On Appeal from Cause No. DC-13-11870 14 Judicial District Court, Dallas Couty, Texas Hon. Eric Moyé, Judge Presiding SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT TO THE HONORABLE COURT OF APPEALS:

COMES NOW, Appellant Hassan Parsa, respectfully moves this Honorable Court

for a second extension of time in which to file his brief, stating as follows: The court below is the 14th District Court, Dallas County, Texas.

1. This is an appeal from an order dated June 9, 2014.

2. A notice of appeal was timely filed on July 3, 2014. The Clerk’s Record

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was filed on August 5, 2014. The Reporter’s Record was filed July 25, 2014. *2 By order dated August 25, 2014, this appeal was abated due to the

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bankruptcy of Appellant. By order dated March 18, 2015, the stay was lifted by this

Court and Appellant’s brief was due to be filed April 15, 2015.

5. By Order dated April 15, 2015, pursuant to extension, Appellant’s Brief is

currently due to be filed with this Court on May 17, 2015.

6. It is impossible to adequately prepare the brief of Appellant in the current

time allowed. Although counsel for Appellant was counsel in the trial court, the delay

caused by the bankruptcy has caused the record to go cold, and it must be thoroughly re-

reviewed. Further, counsel’s spouse had surgery on March 30, 2015, leaving her

incapacitated for a period of two months. During this period counsel has also had to

prepare and file a Reply to Response to Petition for Review in the Supreme Court (filed

April 30, 2015) in Goodwin v. QuikTrip Corp. , No. 14-1076. Counsel for Appellant

requests additional time to adequately prepare the brief of Appellant in the current time

allotted.

7. The extension sought in this motion is not sought solely for purposes of

delay, but only so that justice may be done. Counsel for Appellee was asked if he opposed this motion on Thursday,

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May 14, 2015. As of Monday, May 18, 2015, no response has been received. An extension of thirty (30) days is sought by this motion.

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WHEREFORE, PREMISES CONSIDERED , Appellant respectfully requests

that the time in which he may file his Brief be extended to and including June 15, 2015,

and for such other and further relief to which he may be entitled at law or in equity.

Respectfully submitted, /s/ Mark Donheiser RANDAL MATHIS State Bar No. 13194300 MARK DONHEISER State Bar No. 05974800 M ATHIS & D ONHEISER 1412 Main Street, Suite 2600 Dallas, TX 75202 Telephone: 214.303.1919 Facsimile: 214.303.0399 ATTORNEYS FOR HASSAN PARSA CERTIFICATE OF CONFERENCE Counsel for Appellee, Jerrod David, has not responded to a May 14, 2015 request

for conference on this motion

Signed this 18 day of May, 2015.

/s/ Mark Donheiser MARK DONHEISER *4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has

been forwarded to all other known counsel of record as listed below, via facsimile, in

accordance with the Texas Rules of Civil Procedure on this 18 day of May, 2015.

Mr. Jerrod L. Davis

Brady & Brady, PLLC

6440 N. Central Expressway, Suite 610

Dallas, Texas 75206

/s/ Mark Donheiser MARK DONHEISER