ACCEPTED 05-23-01261-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 3/11/2024 10:25 AM RUBEN MORIN CLERK No. 05-23-01261-CV IN THE FIFTH COURT OF APPEALS FILED IN 5th COURT OF APPEALS DALLAS, TEXAS DALLAS, TEXAS 3/11/2024 10:25:04 AM Ruben Morin PRIMALEND CAPITAL PARTNERS, LP AND LNCMJ MANAGEMENTClerk , LLC, Appellants, V. MEIR BENIT, INDIVIDUALLY AND RON BENIT, AS TRUSTEE OF THE MEIR BENIT TRUST, Appellees.

On Appeal from the 95th Judicial District Court of Dallas County Cause No. DC-21-06229 UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF

Pursuant to Texas Rules of Appellate Procedure 10.5 and 52.9, Appellants PrimaLend Capital Partners, LP and LNCMJ Management, LLC respectfully file this Unopposed Second Motion for Extension of Time to File its Opening Brief. The current deadline for filing the Brief is March 22, 2024. Appellants requests a thirty- day extension of time for a new deadline of April 22, 2024.

The undersigned lead appellate counsel for Appellants is currently out of the country on a long-planned family trip. In addition, I have had to devote time and attention to the following matters: 1. Preparation of Motion for Rehearing in Repsol Oil & Gas USA, LLC v. Matrix Petroleum, LLC, in the Fourth Court of Appeals, No. 04-18- 00411-CV, due March 13, 2024; 2. Preparation of Appellee’s Brief in West Harbour, LLC v. Orleans Harbour Homeowners Association, Inc., in the Fourteenth Court of Appeals, No. 14-23-00249-CV, due March 18, 2024 (extension may be requested); 3. Preparation of Appellee’s Brief in PBAC 507 Holdings, LLC v. Broadview Properties, LLC, in the Third Court of Appeals, No. 03-23- 00411-CV, due March 25, 2024 (extension is being requested); 4. Preparation for trial Palo Duro G&P (Oklahoma) L.P., et al. v. Wheeler County Appraisal District, in the 31st Judicial District Court of Hemphill County, Texas, No. 14328, set for April 8, 2024; and 5. Preparation for trial Palo Duro G&P (Oklahoma) L.P., et al. v. Wheeler County Appraisal District, in the 31st Judicial District Court of Hemphill County, Texas, No. 7755, set for April 22, 2024.

Unless otherwise indicated, the deadlines were scheduled prior to the deadline sought to be extended, have already been extended previously, and/or are difficult or not possible to reschedule due to the circumstances surrounding the particular deadline. These responsibilities further support the requested extension. This extension is not sought for the purposes of delay. One prior extension has been granted for this deadline.

As set forth in the Certificate of Conference below, counsel for this motion for extension of time is unopposed.

For these reasons, Appellants request that the Motion for Extension of Time be granted and the deadline for their opening brief be extended 30 days to April 22, 2024.

Respectfully submitted, /s/ Marcy Hogan Greer Marcy Hogan Greer State Bar No. 08417650 [email protected] ALEXANDER DUBOSE & JEFFERSON LLP Congress Ave., Suite 2350 Austin, Texas 78701 Telephone: (512) 482-9300 Facsimile: (512) 482-9303 R. Scott Seifert Texas Bar No. 24003860 [email protected] Laurie N. Patton Texas Bar No. 24078158 [email protected] Kimberly H. Kerns Texas Bar No. 24071217 [email protected] SPENCER FANE LLP 5700 Granite Parkway, Suite 650 Plano, Texas 75024 Telephone: (214) 750-3610 Facsimile: (214) 750-3612 Jacob Sparks Texas Bar No. 24066126 [email protected] NELSON MULLINS RILEY & SCARBOROUGH LLP 5830 Granite Parkway, Suite 1000 Plano, Texas 75024 Telephone: (469) 484-4758 ATTORNEYS FOR APPELLANTS

CERTIFICATE OF CONFERENCE I certify that I conferred with Brian P. Shaw, counsel for appellees, on March 10, 2024, and his clients do not oppose the relief requested in this motion.

/s/ Marcy Hogan Greer Marcy Hogan Greer

CERTIFICATE OF SERVICE I certify that on March 11, 2024, a true and correct copy of this motion is served via electronic service through eFile.TXCourts.gov on parties through counsel of record.

/s/ Marcy Hogan Greer Marcy Hogan Greer

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.

Mandy Patterson on behalf of Marcy Greer Bar No. 8417650 [email protected] Envelope ID: 85402877 Filing Code Description: Motion Filing Description: Unopposed Second Motion for Extension of Time to File Appellants' Brief Status as of 3/11/2024 10:37 AM CST Associated Case Party: PrimaLend Capital Partners, LP Name BarNumber Email TimestampSubmitted Status Mandy Patterson [email protected] 3/11/2024 10:25:04 AM SENT Marcy HoganGreer [email protected] 3/11/2024 10:25:04 AM SENT Stacey Jett [email protected] 3/11/2024 10:25:04 AM SENT R. ScottSeifert [email protected] 3/11/2024 10:25:04 AM SENT Laurie N.Patton [email protected] 3/11/2024 10:25:04 AM SENT Kimberly H.Kerns [email protected] 3/11/2024 10:25:04 AM SENT Jacob Sparks [email protected] 3/11/2024 10:25:04 AM SENT Cathi Trullender [email protected] 3/11/2024 10:25:04 AM SENT

Associated Case Party: Meir Benit Name BarNumber Email TimestampSubmitted Status Brian P.Shaw [email protected] 3/11/2024 10:25:04 AM SENT Daniel JamesBennett [email protected] 3/11/2024 10:25:04 AM SENT Tania Sethi [email protected] 3/11/2024 10:25:04 AM ERROR

Case Contacts Name BarNumber Email TimestampSubmitted Status Brent Rubin [email protected] 3/11/2024 10:25:04 AM SENT Maria Kountz [email protected] 3/11/2024 10:25:04 AM ERROR Whitney Martinez [email protected] 3/11/2024 10:25:04 AM ERROR