Royal Bengal Construction, Inc. v. United Rentals, Inc.

ACCEPTED 15-25-00053-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/6/2025 3:59 PM NO. 15-25-00053-CV CHRISTOPHER A. PRINE CLERK ______________________ FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS IN THE 6/6/2025 3:59:02 PM COURT OF APPEALS CHRISTOPHER A. PRINE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN Clerk ______________________

ROYAL BENGAL CONSTRUCTION, INC. v. UNITED RENTALS, INC. Appealed from 191ST Judicial District Court Trial Court Cause No. DC-24-02808 in Dallas County, Texas

APPELLANT’S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE PRINCIPAL BRIEF

TO THE HONORABLE COURT OF APPEALS APPELLANT, by and through counsel, file this SECOND MOTION TO EXTEND TIME TO FILE BRIEF and would show this Court the following: BACKGROUND & RELIEF REQUESTED 1. Appellant’s Brief on the merits is due on June 6, 2025.

2. Appellant has previously requested one extension of its Principal Brief.

3. Appellee requests a 17-day extension of its APPELLANT’S BRIEF due date to Monday, June 23, 2025.

MOTION FOR EXTENSION OF TIME PAGE 1 OF 4 ATTEMPTS TO CONFERENCE 4. Counsel for Appellee is Unopposed.

BACKGROUND 5. Appellant and Appellee, through counsel, have negotiated a settlement agreement that conditions release of the judgment—which would resolve the issues between the parties—on a single, timely payment that is to be paid prior to Monday, June 23, 2025.

6. As a way to minimize attorney’s fees on the parties and incurred by the parties and respective attorneys, additional time would permit the parties to fully resolve this matter without having to prepare briefs.

CAUSES FOR EXTENSION 7. Appellant needs additional time because the parties have reached a settlement agreement that once payment has been made by Appellant would alleviate the need for this appeal.

8. During this time, Appellant desired to conserve attorney resources and would need additional time to prepare its Appellant’s brief in the unlikely even the parties do not reach a settlement.

9. This extension is not sought solely for delay, not sought for needless delay, or to be used as an instrument of oppression against Appellant.

MOTION FOR EXTENSION OF TIME PAGE 2 OF 4 10. This extension is sought to allow adequate time to fully and adequately respond to Appellant’s brief and so that justice may be done.

11. Neither party will be prejudiced by the extension.

12. Both parties will be prejudiced—by not granting the extension—because then both sides might otherwise have to devote resources to prosecuting this appeal while also working toward a resolution.

PRAYER FOR RELIEF Wherefore, premises considered, Movant prays that this Court will GRANT this motion, and prepare an ORDER moving the due date for Movant’s Brief forward days, from its current due date of June 6, 2025, to June 23, 2025.

Respectfully Submitted.

By: /s/ William Knisley WILLIAM KNISLEY SBOT No. 24095728 [email protected] KNISLEY, PLLC PO BOX 803710 Dallas TX 75380 (T) 972-925-9225 ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of this document has been E- Served on all parties or their counsel of record through the Texas E-File System via their email address on file on 6/6/2025. /s/ William Knisley

MOTION FOR EXTENSION OF TIME PAGE 3 OF 4 CERTIFICATE OF CONFERENCE The undersigned certifies that counsel for Appellee is unopposed to this Motion.

/s/ William Knisley

MOTION FOR EXTENSION OF TIME PAGE 4 OF 4 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.

Envelope ID: 101735886 Filing Code Description: Motion Filing Description: Unopposed Motion to Extend Time Status as of 6/6/2025 4:37 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William Knisley [email protected] 6/6/2025 3:59:02 PM SENT Matt Garcia [email protected] 6/6/2025 3:59:02 PM SENT Tracy East [email protected] 6/6/2025 3:59:02 PM SENT