# Daniel Leon Stein v. John Reger and SHU W. Reger > Texas Court of Appeals, 1st District (Houston) · November 9, 2015 URL: https://www.frixlaw.com/law-library/cases/4073233 ## Case - **Court:** Texas Court of Appeals, 1st District (Houston) - **Decided:** November 9, 2015 - **Precedential status:** Published - **Opinion:** Opinion - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4073233 ## Opinion text ACCEPTED 01-15-00470-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 11/9/2015 5:11:59 PM CHRISTOPHER PRINE CLERK NO. 01-15-00470-CV FILED IN 1st COURT OF APPEALS In The First Court of Appeals HOUSTON, TEXAS Houston, Texas 11/9/2015 5:11:59 PM CHRISTOPHER A. PRINE Clerk DANIEL LEON STEIN, Appellant, V. JOHN REGER and SHU W. REGER, Appellees. On Appeal from the 281st District Court Harris County, Texas Trial Court Cause No. 2014-25605 UNOPPOSED THIRD MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE COURT OF APPEALS: Appellant, Daniel Leon Stein, files this unopposed third motion for extension of time to file his brief, under Texas Rules of Appellate Procedure 38.6(d) and 10.5(b)(1): A. INTRODUCTION. 1. This is an appeal from a summary judgment. 2. Appellant’s brief is currently due November 9, 2015. 3. This Court ordered the parties to mediation. Though the case has not settled yet, the parties are in good faith negotiations, and expect the matter to be resolved soon. 4. Appellant has sought and received two thirty day extensions. 5. This motion seeks an additional time of 30 days, up to and including December 9, 2015. B. BASES FOR EXTENSIONS. 6. In addition to attempting to prepare the brief in this case, Mr. Kelly has been working on the following deadlines: * Prepared a brief in New Hampshire Insurance Company v. Candis Mora, el al., Cause No. 01-15-00406-CV, in the First Court of Appeals, Houston, Texas, filed on October 22, 2015; * Preparing a response and for a hearing on a motion to compel in Carolyn Jodel Trotter v. River City Bus Company, LLC, River City Coaches, Inc. and Maclovio Adams, Jr., Cause No. 2014-CI-10152, in the 45th Judicial District Court, Bexar County, San Antonio, on November 10, 2015; * Preparing for a response to emergency motion in Carolyn P. Austin v. Coface Seguro De Credito Mexico, S.A. DE C.V., et al., Cause No. 01- 15-00760-CV, in the First Court of Appeals, Houston, Texas; * Preparing a brief on the merits in Brenda Ponce and Ricco Gonzalez, as Natural Parents, Next Friends and Legal Guardians of E.G., a minor v. Memorial Hermann Health System d/b/a Memorial Hermann Memorial City Hospital, Cause No. 15-0042, in the Supreme Court of Texas, due on November 12, 2015; and * Preparing for hearing on a motion for new trial/ motion for reconsideration of summary judgment in Carto Properties, LLC, Jen Marie Rau, Individually, Key Maps, Inc. and The Jen Marie Rau Life Insurance v. Briar Capital, L.P., et al., Cause No. 2015-09664, in the 11th Judicial District Court, Harris County, on November 16, 2015. C. PRAYER. 7. Therefore, appellant asks that the Court grant his request for an extension of 30 days to file his brief, or up to and including December 9, 2015. Respectfully submitted, KELLY, DURHAM & PITTARD, L.L.P. By: /s/ Peter M. Kelly Peter M. Kelly (Lead Counsel) State Bar No. 00791011 1005 Heights Boulevard Houston, Texas 77008 Telephone: 713.529.0048 Facsimile: 713.529.2498 Email: pkelly@texasappeals.com THE LEON LAW FIRM, P.C. By: /s/ Carlos Leon Carlos A. Leon State Bar No.00794157 Piero A. Garcia State Bar No.24090112 Comerica Bank Building One Sugar Creek Center Blvd., Ste. 980 Telephone: 281.980.4529 Facsimile: 281.980.4530 Counsel for Appellant Daniel Leon Stein CERTIFICATE OF CONFERENCE I, Peter M. Kelly, certify that I have conferred with opposing counsel, and Robert Browning does not oppose this request for an extension of time. /s/ Peter M. Kelly Peter M. Kelly CERTIFICATE OF COMPLIANCE Relying on the word count function in the word processing software used to produce this document, I certify that the number of words in this motion (excluding any caption, signature, proof of service, and certificate of compliance) is 378. This motion complies with the typeface requirements of TRAP 9 because: WordPerfect X6 in 14-point Aldine401 BT. /s/ Peter M. Kelly Peter M. Kelly CERTIFICATE OF SERVICE A true and correct copy of this Unopposed Motion for Extension has been forwarded to all counsel of record on November 9, 2015, as follows: Kenneth G. Engerrand (Lead Counsel) Robert M. Browning James L. Silliman BROWN SIMS, P.C. 1177 West Loop South, Tenth Floor Houston, Texas 77027-9007 kengerrand@brownsims.com rbrowning@brownsims.com jsilliman@brownsims.com Counsel for Appellees John Reger and Shu W. Reger /s/ Peter M. Kelly Peter M. Kelly --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4073233. Public record. Not legal advice.