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 9/5/2025 1:03 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 9/5/2025 1:03:09 PM __________________________________________________________________ CHRISTOPHER A. PRINE Clerk Firoz Dhamani, Appellant v. Mustapha Oulad-Chikh, derivatively on behalf of GLOBAL REAL ESTATE, LLC, Appellee __________________________________________________________________ APPELLANT’S UNOPPOSED THIRD 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 Third 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 Court granted Appellant’s second unopposed extension request and moved the deadline for Appellant’s brief to September 15, 2025.

7. The parties remain in settlement negotiations and are negotiating and exchanging the necessary documents they must ultimately execute 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, restructuring the ownership of their LLC, unwinding their other transactions, and effectuating the sale of the “Wagon Wheel” property in Texas and another large property in Tennessee to third- parties – a complicated set of transactions involving nearly 40 financing and conveyance documents to ensure all parties’ interests are protected. The scope of the transactions that the parties are negotiating has expanded since Appellant last sought relief from this Court. Previously, not all financing and conveyance documents had been drafted; currently, the terms, conditions, and any necessary third-party involvement to effectuate the parties’ deal, are being negotiated.

8. 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 previous motions for continuance, which the Court granted.

9. 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. Once again, Appellee does not oppose the extension.

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

11. For the reasons stated above, Appellant seeks an extension from September 15, 2025 to October 17, 2025 to file his Brief of Appellant, should one prove necessary.

12. The undersigned conferred with opposing counsel on September 3, 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 October 17, 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 September 3, 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 September 5, 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 510 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: 105260148 Filing Code Description: Motion Filing Description: APPELLANTS UNOPPOSED THIRD MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Status as of 9/5/2025 1:16 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Brian K.Norman [email protected] 9/5/2025 1:03:09 PM SENT Michael L.Hood [email protected] 9/5/2025 1:03:09 PM SENT Daniela Rials [email protected] 9/5/2025 1:03:09 PM SENT Russell DePalma [email protected] 9/5/2025 1:03:09 PM SENT Julia Cain [email protected] 9/5/2025 1:03:09 PM SENT David Mizgala [email protected] 9/5/2025 1:03:09 PM SENT Jesse Hoffman [email protected] 9/5/2025 1:03:09 PM SENT Asher Miller [email protected] 9/5/2025 1:03:09 PM SENT