TO THE HONORABLE THIRD COURT OF APPEALS:

Pursuant to Tex. R. App. P. 10.5(b) and 38.6(d), the Appellant and Cross-

Appellee, Elness, Swenson, Graham Architects, Inc. (“ESG”), files this Unopposed

Motion to Extend Time to File Appellant’s Reply Brief. ESG’s reply brief is

currently due on July 1, 2015. Counsel for ESG requests a 15-day extension of

time to file its brief, making the brief due on July 16, 2015. This is the first request

for extension of time to file ESG’s reply brief. ESG and RLJ each previously

requested one 30-day extension of time to file the Appellant’s and Cross-

Appellant’s opening briefs and one 30-day extension of time to file corresponding

response briefs.

In addition to the routine matters that counsel must attend to in daily

practice, counsel for ESG is preparing for the following matters:

1. Mediation of six related cases for breach of contractual duties involving

healthcare services on July 7, 2015;

2. Poulos v. Neidich , No. 2013-CA-11693, in the Circuit Court for the

Fifteenth Judicial Circuit in Palm Beach County Florida, Preparation for Trial Setting on August 17, 2015; and 3. Suncoast Post-Tension v. Peter Scoppa, et al. , No. 4:13-cv-3125, in the

United States District Court for the Southern District of Texas, preparation for docket call and trial on August 28, 2015.

Counsel for ESG seeks this extension of time to be able to prepare a cogent

and succinct brief to aid this Court in its analysis of the issues presented. This

request is not sought for delay but so that justice may be done.

Counsel for ESG has conferred with Michael W. Huddleston, counsel for the

Cross-Appellant, and he has indicated that his client does not oppose this motion.

All facts recited in this motion are within the personal knowledge of the

counsel signing this motion, therefore no verification is necessary under Texas

Rule of Appellate Procedure 10.2.

PRAYER FOR RELIEF For the reasons set forth above, ESG requests that this Court grant this

Unopposed Motion to Extend Time to File Appellant’s Reply Brief and extend the

deadline for filing Appellant’s Reply Brief up to and including July 16, 2015. ESG

requests all other relief to which it may be entitled.

Respectfully submitted, PC By: /s/ Weston M. Davis Gregory N. Ziegler Texas Bar No. 00791985 GZiegler@MacdonaldDevin.com Steven R. Baggett Texas Bar No. 01510680 GZiegler@MacdonaldDevin.com Weston M. Davis Texas Bar No. 24065126 WDavis@MacdonaldDevin.com 1201 Elm Street 214.744.3300 telephone 214.747.0942 facsimile Attorneys for Appellant Elness, Swenson, Graham Architects, Inc. ERTIFICATE OF S ERVICE

The undersigned attorney certifies that a true and correct copy of the

foregoing Unopposed Motion to Extend Time to File Appellant’s Reply Brief was

served on all counsel of record in accordance with the Texas Rules of Appellate

Procedure via e-Filing, on June 29, 2015.

/s/ Weston M. Davis ERTIFICATE OF C ONFERENCE Pursuant to Tex. R. App. P. 10.1(5), I certify that counsel for ESG conferred

with opposing counsel who indicated that his client does not oppose this motion.

/s/ Weston M. Davis