ACCEPTED 01-14-00871-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 2/23/2015 12:46:20 PM CHRISTOPHER PRINE CLERK No. 01-14-00871-CV PLAYA VISTA LP, MORGAN- § FILED IN 1st COURT OF APPEALS MULTI FAMILY LLC, and SCOTT § HOUSTON, TEXAS MORGAN § 2/23/2015 12:46:20 PM Appellant § CHRISTOPHER A. PRINE § Clerk v. § § COURT OF APPEALS OF TEXAS LAKESIDE RE, LP, GSRE, INC., § and, AVI RON § FIRST DISTRICT Appellee §

UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLATE BRIEF

Appellants, Playa Vista LP, Morgan-Multi Family LLC, and Scott Morgan, asks the Court to extend the time to file their Appellate Brief.

Introduction 1. This motion is filed before the Appellate Brief is due. There is no specific deadline to file this motion to extend time. See Tex. R. App. Proc. 38.6(d).

2. The parties have agreed to this motion.

Argument & Authorities 3. The Court may grant an extension of time under Texas Rule of Appellate Procedure 38.6(d) and 10.5(b).

4. The deadline to file the Appellate Brief is February 26, 2015. Appellants request an additional thirty (30) days to file the Appellate Brief, extending the deadline to Monday, March 30, 2015.

5. For purposes of previous and upcoming scheduling conflicts, counsel for Appellants request an extension.

6. An extension/stay was previously requested due to summary judgment hearings in the 270th Judicial District Court of Harris County in this cause, causing the case to be abated. The appeal was reinstated last month. Therein, this is Appellants’ first request for an extension to file.

Conclusion and Prayer 7. For the reasons stated above, Appellants ask the Court to grant an extension of time to file the Appellate Brief until March 30, 2015.

Respectfully Submitted, PARANJPE & MAHADASS LLP /s/ Tej Paranjpe___________ Tej R. Paranjpe State Bar Number: 24071829 3701 Kirby, Suite 530 Houston, Texas 77098 832.667.7700 Telephone 832.202.2018 Facsimile [email protected] ATTORNEY FOR APPELLANTS CERTIFICATE OF CONFERENCE I certify that I have conferred with opposing counsel, Jerry Hecht, by email, and he has agreed and is unopposed to Appellant’s Motion to Extend Time to File Appellate Brief.

/s/ Tej Paranjpe_________ TEJ R PARANJPE CERTIFICATE OF SERVICE I hereby certify that, in accordance with Rule 9.5 of the Texas Rules of Appellate Procedure, I have served the foregoing document upon the following parties by facsimile or email correspondence: Jerry Hecht [email protected] Dated: February 23, 2015 /s/ Tej Paranjpe_________ TEJ R PARANJPE