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 7/11/2025 3:07 PM CHRISTOPHER A. PRINE No. 15-25-00020-CV CLERK FILED IN 15th COURT OF APPEALS IN THE FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/11/2025 3:07:10 PM 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 SECOND 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 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 July 28, 2025.
Appellants requests a thirty (30) day extension of time up to and including August 27, 2025, to file Appellants’ Reply Brief. This is Appellants’ second 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 September 11, 2025.
• No. 24-0541; Albertson Companies, Inc., et al. v. County of Dallas; in the Supreme Court of Texas—Reply on the Merits due on July 11, 2025.
• No. 15-25-00109-CV; In re Storable, Inc., et al; in the Fifteenth Court of Appeals, Austin, Texas—Reply to response that is due on July 11, 2025.
• Out-of-state participation in the Texas Association of Defense Counsel’s summer conference—July 17-18, 2025. • No. DC-24-21597; Louis Williams v. Amazon Services, LLC; in the 68th Judicial District of Dallas County, Texas—Motion to Dismiss hearing anticipated to occur in early August 2025.
• No. 23-0607; Renaissance Medical Foundation v. Lugo; in the Supreme Court of Texas—Motion for Partial Rehearing due on August 8, 2025.
• No. D-202-CV-2024-03337; City Mobile Group, LLC v. WW Healthcare, LLC, et al.; in the Second District Court of New Mexico—Scheduling Conference on August 14, 2025.
PRAYER Appellants pray that the Court grant this Motion and extend the time to file Appellants’ Reply up to and including Wednesday, August 27, 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 11th day of July, 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: 103041640 Filing Code Description: Motion Filing Description: Second MET Status as of 7/11/2025 3:23 PM CST Associated Case Party: Storable, Inc. Name BarNumber Email TimestampSubmitted Status Cathy Hodges [email protected] 7/11/2025 3:07:10 PM SENT Dale Wainwright [email protected] 7/11/2025 3:07:10 PM SENT Justin Bernstein [email protected] 7/11/2025 3:07:10 PM SENT Ray Torgerson [email protected] 7/11/2025 3:07:10 PM SENT Carolyn Reed [email protected] 7/11/2025 3:07:10 PM SENT Jonna Summers [email protected] 7/11/2025 3:07:10 PM SENT Lakshmi Kumar [email protected] 7/11/2025 3:07:10 PM SENT Dolores Brunelle [email protected] 7/11/2025 3:07:10 PM SENT Liza Eoff [email protected] 7/11/2025 3:07:10 PM SENT Neil KentonAlexander [email protected] 7/11/2025 3:07:10 PM SENT
Associated Case Party: SafeLease Insurance Services, LLC Name BarNumber Email TimestampSubmitted Status Yetter Coleman [email protected] 7/11/2025 3:07:10 PM SENT Delonda Dean [email protected] 7/11/2025 3:07:10 PM SENT Cody Coll [email protected] 7/11/2025 3:07:10 PM SENT Courtney Smith [email protected] 7/11/2025 3:07:10 PM SENT Luke A.Schamel [email protected] 7/11/2025 3:07:10 PM SENT Christopher Hilton [email protected] 7/11/2025 3:07:10 PM SENT Judd Stone [email protected] 7/11/2025 3:07:10 PM SENT Alyssa Smith [email protected] 7/11/2025 3:07:10 PM SENT Bonnie Chester [email protected] 7/11/2025 3:07:10 PM 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: 103041640 Filing Code Description: Motion Filing Description: Second MET Status as of 7/11/2025 3:23 PM CST Associated Case Party: SafeLease Insurance Services, LLC Bonnie Chester [email protected] 7/11/2025 3:07:10 PM SENT Alexander Dvorscak [email protected] 7/11/2025 3:07:10 PM SENT Shannon Smith [email protected] 7/11/2025 3:07:10 PM SENT R. Paul Yetter [email protected] 7/11/2025 3:07:10 PM SENT Susanna R.Allen [email protected] 7/11/2025 3:07:10 PM SENT Rosalinda Luna [email protected] 7/11/2025 3:07:10 PM SENT
Case-law data current through December 31, 2025. Source: CourtListener bulk data.