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 bkn@snlegal.com
Michael L. Hood
mhood@snlegal.com
Russell J. DePalma
rjd@snlegal.com
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

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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.

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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.

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Respectfully submitted,

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

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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

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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 bkn@snlegal.com 9/5/2025 1:03:09 PM SENT

Michael L.Hood mhood@snlegal.com 9/5/2025 1:03:09 PM SENT

Daniela Rials der@snlegal.com 9/5/2025 1:03:09 PM SENT

Russell DePalma rjd@snlegal.com 9/5/2025 1:03:09 PM SENT

Julia Cain jec@snlegal.com 9/5/2025 1:03:09 PM SENT

David Mizgala djm@snlegal.com 9/5/2025 1:03:09 PM SENT

Jesse Hoffman jhoffman@mccathernlaw.com 9/5/2025 1:03:09 PM SENT

Asher Miller amiller@mccathernlaw.com 9/5/2025 1:03:09 PM SENT