Firoz Dhamani v. Mustapha Oulad-Chikh, Derivatively on Behalf of Global Real Estate, LLC

ACCEPTED 15-25-00103-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/7/2025 12:34 PM IN THE FIFTEENTH COURT OF APPEALSCHRISTOPHER A. PRINE OF TEXAS CLERK __________________________________________________________________ FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS NO. 15-25-00103-CV 8/7/2025 12:34:43 PM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk Firoz Dhamani, Appellant v. Mustapha Oulad-Chikh, derivatively on behalf of GLOBAL REAL ESTATE, LLC, Appellee __________________________________________________________________ APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT __________________________________________________________________ On Appeal from Texas Business Court, First District; Hon. Andrea K. Bouressa, Presiding Judge. __________________________________________________________________

ORAL ARGUMENT Brian K. Norman CONDITIONALLY REQUESTED [email protected] Michael L. Hood [email protected] Russell J. DePalma [email protected] SHAMOUN & NORMAN, LLP 1800 Valley View Lane, Ste. 200 Farmers Branch, TX 75234 (214) 987-1745 ATTORNEYS FOR APPELLANT TO THE HONORABLE COURT OF APPEALS: COMES NOW, Appellant Firoz Dhamani, Defendant below, and files this, his Second Motion for Extension of Time to File Brief of Appellant. In support of this motion, Appellant would show the following: 1. Appellee (Plaintiff in the trial court) does not oppose the relief sought herein.

2. On June 12, 2025, Appellant filed his Notice of Appeal.

3. On June 23, 2025, this Court notified the parties that the Reporter’s Record had been filed. Because the Clerk’s Record had been filed earlier, the Reporter’s Record filing commenced the briefing schedule.

4. This is an accelerated appeal, therefore the deadline for Appellant’s brief is 20 days after the Court receives the full appellate record, or was initially Monday July 14, 2025.

5. The Court granted Appellant’s first unopposed extension request and moved the deadline for Appellant’s brief to August 13, 2025.

6. The parties have been in settlement negotiations and seek to reach an amicable resolution to their dispute. As part of the settlement, and conclusion of their dispute, the parties are negotiating securitized loans on properties in multiple states, the dissolution of their LLC, unwinding their other transactions, and effectuating the sale of the “Wagon Wheel” property in Texas to a third-party – a complicated set of transactions involving more than financing and conveyance documents to ensure all parties’ interests are protected. The parties have exchanged drafts of about 20 necessary documents, with more to circulate in the coming days.

7. Appellant previously represented to this Court that “[t]he negotiations are complex because the business that is the subject of the parties’ dispute owns properties in multiple states that will be affected by any resolution.” This conclusion has been reinforced since Appellant filed his first motion for continuance, which the Court granted.

8. Once again, to ensure the parties focus their energies on reaching an accord, and employ their attorneys primarily for resolving their dispute instead of perpetuating it, Appellant seeks an extension of his briefing deadline. Appellee again does not oppose the extension and is of like mind.

9. Any settlement between the parties will terminate this appeal and therefore obviate any further need for this proceeding.

10. For the reasons stated above, Appellant seeks an extension from August 13, 2025 to September 15, 2025 to file his Brief of Appellant, should one prove necessary.

11. The undersigned conferred with opposing counsel on August 6, 2025, and Appellee does not oppose this request. Appellant does not seek the requested extension for delay but to ensure justice will not be denied.

Therefore, Appellant Firoz Dhamani, prays that this Court grant this motion for extension of time and reset his briefing deadline to September 15, 2025.

Respectfully submitted,

/s/Russell J. DePalma BRIAN K. NORMAN Texas Bar No. 00797161 [email protected] STEVEN R. TITTLE, JR. State Bar No. 24028043 [email protected] MICHAEL L. HOOD State Bar No. 099434435 [email protected] RUSSELL J. DEPALMA Texas Bar No. 00795318 [email protected] DAVID JEFRIE MIZGALA State Bar No. 24031594 [email protected] SHAMOUN & NORMAN, LLP 1800 Valley View Lane, Suite 200 Farmers Branch, Texas 75234 Telephone: (214) 987-1745 Attorneys for Appellant, Firoz Dhamani

CERTIFICATE OF CONFERENCE I certify that on August 6, 2025 I conferred with Jesse Hoffman, counsel for Appellee, who indicated that this motion is unopposed.

/s/Russell J. DePalma RUSSELL J. DePALMA

CERTIFICATE OF SERVICE I certify that, on August 7, 2025, I served a copy of this motion by electronic service and electronic mail upon counsel for Appellee.

/s/Russell J. DePalma RUSSELL J. DePALMA

CERTIFICATE OF COMPLIANCE I certify that this Motion complies with the type size and word count limitations set forth in the Texas Rules of Appellate Procedure because it contains 409 words not exempt from the word count limits and has been generated in a 14-point proportionate-type font.

/s/Russell J. DePalma RUSSELL J. DePALMA

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: 104097267 Filing Code Description: Motion Filing Description: Appellant's Unopposed 2nd Motion for Extension of Time to File Brief Status as of 8/7/2025 1:03 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Brian K.Norman [email protected] 8/7/2025 12:34:43 PM SENT Michael L.Hood [email protected] 8/7/2025 12:34:43 PM SENT Daniela Rials [email protected] 8/7/2025 12:34:43 PM SENT Russell DePalma [email protected] 8/7/2025 12:34:43 PM SENT Julia Cain [email protected] 8/7/2025 12:34:43 PM SENT David Mizgala [email protected] 8/7/2025 12:34:43 PM SENT Jesse Hoffman [email protected] 8/7/2025 12:34:43 PM SENT Asher Miller [email protected] 8/7/2025 12:34:43 PM SENT