Texas Court of Appeals, 15th District, 2025

Storable, Inc.; RedNova Labs, Inc. (d/B/A storEDGE); Sitelink Software, LLC; Easy Storage Solutions, LLC; Bader Co.; And Property First Group, LP v. Safelease Insurance Services, LLC

Texas Court of Appeals, 15th District · Decided May 23, 2025

Opinion

ACCEPTED 15-25-00020-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/23/2025 10:43 AM No. 15-25-00020-CV CHRISTOPHER A. PRINE CLERK In the Court of Appeals 15th COURT FILED IN OF APPEALS for the Fifteenth Judicial District AUSTIN, TEXAS 5/23/2025 10:43:14 AM Austin, Texas CHRISTOPHER A. PRINE Clerk STORABLE, INC.; REDNOVA LABS, INC. (D/B/A STOREDGE; SITELINK SOFTWARE, LLC; EASY STORAGE SOLUTIONS, LLC; BADER CO.; AND PROPERTY FIRST GROUP, LP, Appellants, V.

SAFELEASE INSURANCE SERVICES, LLC, Appellee.

On Appeal from the Third Division of the Texas Business Court SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF FOR APPELLEE

JUDD E. STONE II State Bar No. 24076720 CHRISTOPHER D. HILTON MICHAEL R. ABRAMS CODY C. COLL State Bar No. 24116214 ALEXANDER M. DVORSCAK STONE HILTON PLLC Congress Ave., Suite 2350 Austin, Texas 78701 [email protected] (737) 465-7248 Counsel for Appellee T O THE H ONORABLE C OURT O F A PPEALS : Plaintiff-Appellee SafeLease Insurance Services, LLC requests a 10-day extension of the time in which to file its responding brief in this Court. One previous extension has been granted. Appellee’s Brief in Response is currently due on Tuesday, May 27, 2025.

Under Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellee requests a 10-day extension of time in which to file its Brief in Response, which would make the new deadline Friday, June 6, 2025. This extension is needed because of the press of other business in which the undersigned counsel has impending trial and appellate court deadlines, including: • Appellant’s Opening Brief, Media Matters for Am., et al. v. X Corp., et al., No. 25-2463 (9th Cir.), filed May 14, 2025; • Reply in Support of Motion to Stay, Media Matters for Am., et al. v. X Corp., et al., No. 3:25-cv-02397 (N.D. Cal.), filed May 16, 2025; • Reply in Support of Motion to Compel, X Corp. v. Media Matters for Am., et al., No. 4:23-cv-01175-O (N.D. Tex.), filed May 19, 2025;

• Supplemental Brief on Requested Topics, X Corp. v. Media Matters for Am., et al., No. 4:23-cv-01175-O (N.D. Tex.), filed May 21, 2025; • Appellee’s Response Brief, Keough v. Kenningham, et al., No. 09-25-00089-CV (Tex. App.—Beaumont), due May 27, 2025; and • Appellant’s Reply Brief, Doe v. U.S. Dep’t of Health & Human Servs., 24-40778 (5th Cir.), due June 2, 2025.

This extension is not requested merely for delay, but rather so that justice may be done. This motion is unopposed.

CONCLUSION AND PRAYER Appellee respectfully requests that the Court grant a 10-day extension of time in which to file a Brief in Response.

Respectfully submitted.

May 23, 2025 /s/ Cody C. Coll Judd E. Stone II Christopher D. Hilton Michael R. Abrams Cody C. Coll Alexander M. Dvorscak STONE HILTON PLLC Congress Ave. Suite 2350 Austin, Texas 78701 [email protected] (737) 465-7248 Counsel for Appellee

CERTIFICATE OF SERVICE On May 23, 2025, this document was electronically filed and served on all counsel.

/s/ Cody C. Coll Cody C. Coll

CERTIFICATE OF CONFERENCE On May 23, 2025, I conferred with Justin Bernstein, appellate counsel for Appellants, via email. Counsel stated the relief requested herein is unopposed.

/s/ Cody C. Coll Cody C. Coll

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.

Rosalinda Luna on behalf of Cody Coll Bar No. 24116214 [email protected] Envelope ID: 101202481 Filing Code Description: Motion Filing Description: Second Unopposed Motion for Extension of Time to File Brief for Appellee Status as of 5/23/2025 10:56 AM CST Associated Case Party: SafeLease Insurance Services, LLC Name BarNumber Email TimestampSubmitted Status Delonda Dean [email protected] 5/23/2025 10:43:14 AM SENT Yetter Coleman [email protected] 5/23/2025 10:43:14 AM SENT Cody Coll [email protected] 5/23/2025 10:43:14 AM SENT Courtney Smith [email protected] 5/23/2025 10:43:14 AM SENT Luke A.Schamel [email protected] 5/23/2025 10:43:14 AM SENT Christopher Hilton [email protected] 5/23/2025 10:43:14 AM SENT Judd Stone [email protected] 5/23/2025 10:43:14 AM SENT Alyssa Smith [email protected] 5/23/2025 10:43:14 AM SENT Bonnie Chester [email protected] 5/23/2025 10:43:14 AM SENT Alexander Dvorscak [email protected] 5/23/2025 10:43:14 AM SENT Shannon Smith [email protected] 5/23/2025 10:43:14 AM SENT R. Paul Yetter [email protected] 5/23/2025 10:43:14 AM SENT Susanna R.Allen [email protected] 5/23/2025 10:43:14 AM SENT Rosalinda Luna [email protected] 5/23/2025 10:43:14 AM SENT

Associated Case Party: Storable, Inc. Name BarNumber Email TimestampSubmitted Status Dale Wainwright [email protected] 5/23/2025 10:43:14 AM SENT Justin Bernstein [email protected] 5/23/2025 10:43:14 AM SENT Ray Torgerson [email protected] 5/23/2025 10:43:14 AM SENT Carolyn Reed [email protected] 5/23/2025 10:43:14 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.