Harbor America Central, Inc. v. William Reeves

ACCEPTED 15-24-00128-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/19/2024 2:16 PM No. 15-24-00128-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE COURT OF APPEALS 15th COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS AUSTIN, TEXAS AUSTIN, TEXAS 12/19/2024 2:16:19 PM CHRISTOPHER A. PRINE Clerk HARBOR AMERICA CENTRAL, INC., Appellant, v. WILLIAM REEVES, Appellee.

On Appeal from the 55th District Court of Harris County, Texas Trial Court No. 2017-25574

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO MOTION TO TRANSFER APPEAL TO THE HONORABLE COURT OF APPEALS: Appellant, Harbor America Central, Inc., respectfully files this unopposed motion for extension of time to file its response to Appellee’s Motion to Transfer Appeal to Fourteenth Court of Appeals, and would show the Court as follows: 1. The present deadline for filing the response is December 26, 2024.

2. Appellant seeks a 30-day extension, until January 25, 2025, to file its response.

3. This is Appellant’s first request for an extension of time to file the response.

4. This motion is unopposed.

5. The parties are now in discussions that may moot the need for action on the motion, and they expect to conclude those discussions in early January.

6. Additionally, the current deadline falls in the midst of the holidays, making it difficult to collaborate on the response.

7. This motion is not filed for the purpose of delay, but to allow counsel adequate time to prepare the response (should it prove necessary to file one).

For these reasons, Appellant respectfully requests an extension of time to file its response until January 25, 2025.

Respectfully submitted, BECK REDDEN LLP By: /s/ Russell S. Post Joshua S. Smith State Bar No. 24093173 [email protected] Russell S. Post State Bar No. 00797258 [email protected] 1221 McKinney Street, Suite 4500 Houston, Texas 77010 Telephone: (713) 951-3700 ATTORNEYS FOR APPELLANT, HARBOR AMERICA CENTRAL, INC.

CERTIFICATE OF CONFERENCE I certify that I conferred with counsel for Appellee concerning this motion, and Appellee’s counsel informed me that Appellee does not oppose the requested extension.

/s/ Russell S. Post Russell S. Post

CERTIFICATE OF SERVICE I hereby certify that on December 19, 2024 a true and correct copy of the foregoing motion has been electronically filed and served on all counsel.

/s/ Russell S. Post Russell S. Post

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Laura Crain on behalf of Russell Post Bar No. 797258 [email protected] Envelope ID: 95513162 Filing Code Description: Motion Filing Description: Unopposed Motion for Extension of Time to File Response to Motion to Transfer Appeal Status as of 12/19/2024 2:24 PM CST Associated Case Party: Harbor America Central, Inc. Name BarNumber Email TimestampSubmitted Status Russell S.Post [email protected] 12/19/2024 2:16:19 PM SENT Joshua S.Smith [email protected] 12/19/2024 2:16:19 PM SENT

Associated Case Party: William Reeves Name BarNumber Email TimestampSubmitted Status Ryan Pigg 24088227 [email protected] 12/19/2024 2:16:19 PM SENT Thomas Holler 24126898 [email protected] 12/19/2024 2:16:19 PM SENT William DavidGeorge [email protected] 12/19/2024 2:16:19 PM SENT Lionel Sims 24107465 [email protected] 12/19/2024 2:16:19 PM SENT Anthony G.Buzbee [email protected] 12/19/2024 2:16:19 PM SENT Chris J.leavitt [email protected] 12/19/2024 2:16:19 PM SENT Anthony Buzbee 24001820 [email protected] 12/19/2024 2:16:19 PM ERROR