FILED 14-0764 5/5/2015 12:11:25 PM tex-5154769 SUPREME COURT OF TEXAS BLAKE A. HAWTHORNE, CLERK No. 14-0764 __________________________________________________________________ IN THE SUPREME COURT OF TEXAS __________________________________________________________________ FIRST FINANCIAL INVESTMENT FUND HOLDINGS LLC D/B/A FIRST FINANCIAL INVESTMENT FUND II, LLC, FIRST FINANCIAL ASSET MANAGEMENT, INC. AND RECEIVABLES PERFORMANCE MANAGEMENT, LLC, Petitioners, vs. ANNA MARIE BERRY, AS PERSONAL REPRESENTATIVE FOR THE ESTATE OF PARKER T. BERRY, Respondent. __________________________________________________________________ On Petition for Review from the Eighth District Court of Appeals – El Paso, Texas No. 08-14-00097-CV MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF TO RESPONDENT’S BRIEF ON THE MERITS __________________________________________________________________ Steven R. Dunn 8390 LBJ Freeway Suite 540 Dallas, Texas 75243 214.692.5533 [email protected] Attorney for Petitioners

Motion for Extension -- Page 1 of 1 TO THE HONORABLE SUPREME COURT OF TEXAS: First Financial Investment Fund Holdings LLC a/d/b/a First Financial Investment Fund II, LLC, First Financial Asset Management, Inc. and Receivables Performance Management, LLC (“Petitioners”) file this Motion for Extension of Time to File their Reply Brief to Respondent’s Brief on the Merits under Tex. R. App. P. 10.1, 10.5(b), and 53.7(f). In support of this motion, Petitioners show the following: 1. On February 27, 2015, this Court’s clerk advised the parties of a briefing schedule for briefs on the merit.

2. Petitioners timely filed their Brief on the Merits on March 30, 2015.

Respondent’s filed her Response Brief on April 20, 2015. Petitioners’ Reply Brief is due no later than May 5, 2015. Petitioners request an extension of seven (7) days, until May 12, 2015 to file their Reply Brief to Respondent’s Brief on the Merits. This is Petitioners’ first request for an extension of time to file their Reply Brief.

3. Petitioners rely on the following facts as a reasonable explanation for the requested extension of time: Petitioners’ counsel has been required to devote a considerable amount of time to the continued care of a family member during the past three week time period. To this end, Petitioners’ counsel has had to schedule

Motion for Extension -- Page 2 of 2 appointments and a treatment care plan with doctors, counselors and dieticians for his family member during this period. This family member returned to Dallas on April 24, 2015 from a hospital in Denver, Colorado and resides with Petitioners’ counsel. Since the family member’s return, Petitioners’ counsel has met with her medical professionals on the following dates: May 5, 2015; April 30, 2015; April 29, 2015; April 27, 2015. These meetings have required Petitioners’ counsel to dedicate a great amount of time away from his practice.

4. The undersigned contacted opposing counsel regarding the merits of this motion. Opposing counsel did not return the communication.

Wherefore the premises considered, Petitioners pray that this Court grant this motion for extension of time and grant Petitioners an additional seven (7) days until May 12, 2015 to file their Reply Brief. Petitioners pray for such other and further relief, at law or in equity, to which Petitioners may be duly entitled.

Respectfully submitted, /s/ Steven R. Dunn______________ Steven R. Dunn 8390 LBJ Freeway, Suite 540 Dallas, Texas 75243 Telephone (214) 692.5533 Facsimile (214) 692.5534 [email protected] ATTORNEY FOR PETITIONERS Motion for Extension -- Page 3 of 3 CERTIFICATE OF CONFERENCE As required by Tex. R. App. P. 10.1(a)(5), I certify that I attempted to confer with Kimberly Soard, counsel for Respondent. Counsel for Respondent did not respond to the email communication. Therefore, it is submitted to the Court for its determination.

/s/ Steven R. Dunn______________ Steven R. Dunn

CERTIFICATE OF SERVICE I hereby certify that on May 5, 2015, I electronically filed the foregoing with the Clerk of Court using the efiling system which will send notification of such filing to the following persons: Kimberly F. Soard State Bar No 00797815 LAW OFFICES OF KIMBERLY SOARD, P.C.

3722 Bristleleaf Drive Katy, Texas 77449 /s/ Steven R. Dunn_____________ Steven R. Dunn

Motion for Extension -- Page 4 of 4