Case Information
*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 12/8/2015 4:48:19 PM LISA MATZ Clerk *1 ACCEPTED 05-15-01377-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 12/8/2015 4:48:19 PM LISA MATZ CLERK No. 05-15-01377-CV In the Court of Appeals for the Fifth Judicial District Dallas, Texas VRIDE, INC., F/K/A VPSI, INC., Appellant, v.
FORD MOTOR COMPANY, Appellee. On Appeal from the 116th District Court, Dallas County, Texas, Cause No. DC-14-11247, the Hon. Tonya Parker, presiding UNOPPOSED MOTION TO EXTEND TIME TO FILE BRIEF OF APPELLANT TO THE HONORABLE JUSTICES OF THE FIFTH COURT OF APPEALS:
Comes now, Appellant vRide, Inc., f/k/a VPSI, Inc. (“Appellant”) and files
this Unopposed Motion to Extend Time to File Brief of Appellant . In support of
this Motion, Appellant shows the Court the following:
I. DUE DATE Appellant’s Brief is currently due January 4, 2016. No previous extension
has been sought by Appellant regarding its Brief. Appellant seeks an additional
thirty (30) days until February 3, 2016 to file its Appellant’s Brief. *2 II.
REASONS FOR EXTENSION OF TIME Appellant’s counsel has been involved in other matters and matters with
deadlines that are quickly approaching. In particular:
1. David Keltner assisted in the preparation and filing of a petition
for permission to appeal in the Second Court of Appeals; The
Carmichael Family Trust v. Krone Medical Properties, LP, et al. ,
filed on December 8, 2015;
2. Mr. Keltner is preparing for and attending a hearing in Cause
No. 2060; Mayo Foundation for Medical Education and Research, et
al. v. Courson Oil & Gas, Inc., et al. , in the 31st District Court,
Roberts County, Texas on December 9, 2015;
3. Mr. Keltner is also preparing for and attending a hearing in
Cause No. 153-272310-14; Jennifer Pedroza v. Amanda Hayward, et
al. in the 153rd District Court, Tarrant County, Texas on December
10, 2015;
4. Mr. Keltner is attending a mediation in Cause No. 348-259418-
12; Pamela Hicks, et al. v. Gary Salinski, et al. , in the 348th District
Court, Tarrant County, Texas on December 11, 2015;
5. Mr. Keltner is preparing for and attending an oral argument in
No. 14-10-00708-CV; Port of Houston Authority of Harris County v.
Zachry Construction Corp. , in the Fourteenth Court of Appeals,
Houston, Texas on December 14, 2015;
6. Mr. Keltner is preparing for and attending a hearing in Cause
No. 048-276595-15; BNSF Railway Company v. Standard Steel, LLC ,
in the 48th District Court, Tarrant County, Texas on December 16,
2015; and
7. Mr. Keltner will be out of the office during the holidays
beginning December 21, 2015 and returning on January 4, 2016. *3 III.
EXTENSION SOUGHT IN THE INTEREST OF JUSTICE
The extension sought is not for the purpose of delay, but rather, is sought in
the interest of justice and to allow Appellant to fully brief issues to the Court.
IV. APPELLEE AGREES TO THIS REQUEST Counsel for Appellee Ford Motor Company, Mike Eady, does not oppose
this motion for extension of time.
V. PRAYER FOR EXTENSION Therefore, Appellant requests an extension of time of thirty (30) days, until
February 3, 2016, to file its Brief of Appellant. Appellant does not seek this
extension for the purposes of delay. Instead, Appellant seeks this relief to be able
to fully brief the issues.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court
grant an extension of time to file its Brief of Appellant until February 3, 2016. *4 Respectfully submitted, /s/ David Keltner David E. Keltner State Bar No. 11249500 david.keltner@kellyhart.com April Farris State Bar No. 24069702 april.farris@kellyhart.com K ELLY H ART & H ALLMAN LLP 201 Main Street, Suite 2500 Fort Worth, Texas 76102 817.332.2500—Telephone 817.878.9280—Telecopier Chris C. Pappas State Bar No. 15454300 cpappas@krcl.com Andrew J. Sarne State Bar No. 00797380 asarne@krcl.com Logan R. Burke State Bar No. 24073978 lburke@krcl.com K ANE R USSELL C OLEMAN & L OGAN PC 5051 Westheimer, 10th Floor Houston, Texas 77056 713.425.7400—Telephone 713.425.7700—Telecopier Counsel for vRide Inc., f/k/a VPSI, Inc. *5 CERTIFICATE OF CONFERENCE On December 7, 2015, I contacted counsel for Appellee Ford Motor
Company, Mike Eady, and Appellee is not opposed to this Motion.
/s/ David Keltner David E. Keltner CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above
and foregoing document has been served upon counsel via electronic filing on
December 8, 2015:
Michael W. Eady E. Todd Tracy
meady@thompsoncoe.com ttracy@vehiclesafetyfirm.com
Ronald D. Wamsted Stewart D. Matthews
rwamsted@thompsoncoe.com smatthews@vehiclesafetyfirm.com Andrew G. Counts
T HOMPSON C OE , C OUSINS acounts@vehiclesafetyfirm.com
& I RONS LLP T HE T RACY F IRM
701 Brazos, Suite 1500 5473 Blair Road, Suite 200
Austin, Texas 78701 Dallas, Texas 75231
Counsel for Appellee
Counsel for Appellee /s/ David Keltner David E. Keltner