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
Opinion
ACCEPTED 15-25-00020-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/13/2025 11:59 AM CHRISTOPHER A. PRINE No. 15-25-00020-CV CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/13/2025 11:59:27 AM Storable, Inc.; RedNova Labs, Inc. (d/b/a storEDGE); Sitelink CHRISTOPHER Clerk A. PRINE 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 Cause No. 25-BC03A-0001
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ REPLY BRIEF
GREENBERG TRAURIG, LLP Dale Wainwright State Bar No. 00000049 [email protected] Justin Bernstein State Bar No. 24105462 [email protected] West 6th Street, Suite 2050 Austin, Texas 78701 T: (512) 320-7200 F: (512) 320-7210 COUNSEL FOR APPELLANTS
ACTIVE 711375881v1 TO THE HONORABLE FIFTEENTH COURT OF APPEALS: Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), Appellants file this unopposed motion requesting an extension of time to file Appellants’ Reply Brief.
The current deadline for filing Appellants’ Reply Brief is June 26, 2025.
Appellants requests a thirty (30) day extension of time up to and including July 28, 2025, to file Appellants’ Reply Brief. This is Appellants’ first request for an extension of this deadline. Appellee is unopposed to this requested extension.
Appellants seek an extension not for the purpose of delay, but for adequate time to prepare a cogent brief that will assist the Court. In addition, the following court deadlines of Appellants’ appellate counsel necessitate this additional time, including but not limited to the following: • No. D-1-GN-25-000961; Britteny Nova, et al v. Greystar Development, et al; in the 98th Judicial District Court of Travis County, Texas—Depositions scheduled from June 12, 2025 to June 26, 2025.
• No. 25-BC03A-001; Safelease Insurance Services, LLC v. Storable, Inc., et al; in the Business Court of Texas, Third Division—Petition for Writ of Mandamus may be filed on June 23, 2025.
• No. 14-24-00395-CV; Patriot Contracting, LLC, et al v. HERC Solutions USA, LLC, et al; in the Fourteenth Court of Appeals, Houston, Texas—Reply Brief due on July 2, 2025. • No. 00315; Emily Glass v. B. Braun Medical, Inc., et al; in the Court of Common Pleas of Philadelphia County, First Judicial District of Pennsylvania—Status hearing on July 3, 2025.
• No. 23-0607; Renaissance Medical Foundation v. Lugo; in the Supreme Court of Texas—Motion for Partial Rehearing due on July 9, 2025.
• No. 24-0541; Alberson Companies, Inc., et al. v. County of Dallas; in the Supreme Court of Texas—Reply on the Merits due on July 11, 2025.
PRAYER Appellants pray that the Court grant this Motion and extend the time to file Appellants’ Reply up to and including Monday, July 28, 2025.
Respectfully submitted, GREENBERG TRAURIG, LLP By: /s/Dale Wainwright______ Dale Wainwright State Bar No. 00000049 [email protected] Justin Bernstein State Bar No. 24105462 [email protected] West 6th Street, Suite 2050 Austin, Texas 78701 T: (512) 320-7200 F: (512) 320-7210 COUNSEL FOR APPELLANTS CERTIFICATE OF CONFERENCE I certify that I communicated about this Motion with counsel for Appellee, who advised that Appellee is unopposed to the requested extension of time.
/s/ Justin Bernstein Justin Bernstein CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this Motion was served on all counsel of record by using the Court’s e-filing system on the 13th day of June, 2025.
/s/ Dale Wainwright Dale Wainwright 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.
Sylvia Dominguez on behalf of Dale Wainwright Bar No. 49 [email protected] Envelope ID: 101990837 Filing Code Description: Motion Filing Description: 2025-06-13 COA MET Reply Brief Status as of 6/13/2025 12:07 PM CST Associated Case Party: Storable, Inc. Name BarNumber Email TimestampSubmitted Status Cathy Hodges [email protected] 6/13/2025 11:59:27 AM SENT Dale Wainwright [email protected] 6/13/2025 11:59:27 AM SENT Justin Bernstein [email protected] 6/13/2025 11:59:27 AM SENT Ray Torgerson [email protected] 6/13/2025 11:59:27 AM SENT Carolyn Reed [email protected] 6/13/2025 11:59:27 AM SENT Jonna Summers [email protected] 6/13/2025 11:59:27 AM SENT Lakshmi Kumar [email protected] 6/13/2025 11:59:27 AM SENT Dolores Brunelle [email protected] 6/13/2025 11:59:27 AM SENT Liza Eoff [email protected] 6/13/2025 11:59:27 AM SENT Neil KentonAlexander [email protected] 6/13/2025 11:59:27 AM SENT
Associated Case Party: SafeLease Insurance Services, LLC Name BarNumber Email TimestampSubmitted Status Yetter Coleman [email protected] 6/13/2025 11:59:27 AM SENT Delonda Dean [email protected] 6/13/2025 11:59:27 AM SENT Cody Coll [email protected] 6/13/2025 11:59:27 AM SENT Courtney Smith [email protected] 6/13/2025 11:59:27 AM SENT Luke A.Schamel [email protected] 6/13/2025 11:59:27 AM SENT Christopher Hilton [email protected] 6/13/2025 11:59:27 AM SENT Judd Stone [email protected] 6/13/2025 11:59:27 AM SENT Alyssa Smith [email protected] 6/13/2025 11:59:27 AM SENT Bonnie Chester [email protected] 6/13/2025 11:59:27 AM SENT 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.
Sylvia Dominguez on behalf of Dale Wainwright Bar No. 49 [email protected] Envelope ID: 101990837 Filing Code Description: Motion Filing Description: 2025-06-13 COA MET Reply Brief Status as of 6/13/2025 12:07 PM CST Associated Case Party: SafeLease Insurance Services, LLC Bonnie Chester [email protected] 6/13/2025 11:59:27 AM SENT Alexander Dvorscak [email protected] 6/13/2025 11:59:27 AM SENT Shannon Smith [email protected] 6/13/2025 11:59:27 AM SENT R. Paul Yetter [email protected] 6/13/2025 11:59:27 AM SENT Susanna R.Allen [email protected] 6/13/2025 11:59:27 AM SENT Rosalinda Luna [email protected] 6/13/2025 11:59:27 AM SENT
Case-law data current through December 31, 2025. Source: CourtListener bulk data.