Frisco Summit, LP and Frisco Summit, LP Derivatively and on Behalf of Frisco Multifamily Land Partners, LP v. Frisco Multifamily Land GP, LLC, Carleton Development, Ltd., GH Southwest II, Inc., Frisco Summit I, LP, Frisco Summit I GP, LLC, Salt River Capital, Inc.,Frisco Summit II, LP, Frisco Summit II GP, LLC, Printice L. Gary, Jeffrey D. Fulenchek, and Neal R. Hildebrand

ACCEPTED
15-25-00055-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
9/22/2025 5:02 PM
NO. 15-25-00055-CV CHRISTOPHER A. PRINE
CLERK
IN THE COURT OF APPEALS FOR THE 15TH DISTRICTFILED OF TEXAS
IN
AT AUSTIN, TEXAS 15th COURT OF APPEALS
AUSTIN, TEXAS
__________________________________________________________________
9/22/2025 5:02:32 PM
CHRISTOPHER A. PRINE
FRISCO SUMMIT, LP AND FRISCO SUMMIT, LP DERIVATIVELY
Clerk ON
BEHALF OF FRISCO MULTIFAMILY LAND PARTNERS, LP,
Appellants
vs.
FRISCO MULTIFAMILY LAND GP, LLC; CARLETON DEVELOPMENT,
LTD.; GH SOUTHWEST II, INC.; FRISCO SUMMIT I, LP; FRISCO SUMMIT I
GP, LLC; SALT RIVER CAPITAL, INC.; FRISCO SUMMIT II, LP; FRISCO
SUMMIT II GP, LLC; PRINTICE L. GARY; JEFFREY D. FULENCHEK; AND
NEAL R. HILDEBRANDT,
Appellees.
__________________________________________________________________

Appeal from 493rd District Court
of Dallas County, Texas
__________________________________________________________________

THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLANTS
__________________________________________________________________

Mitchell Madden
State Bar No. 12789350
mmadden@hjmmlegal.com
Holmgren Johnson: Mitchell Madden, LLP
12801 North Central Expressway
Suite 140
Dallas, Texas 75243
(972) 484-7780
(972) 484-7743 Facsimile

COUNSEL FOR APPELLANTS

1 | Pa g e
Appellants Frisco Summit, LP and Frisco Summit, LP derivatively on behalf

of Frisco Multifamily Land Partners, LP (“Appellants”) hereby move the Court for

a 14-day extension of time to file their Brief of Appellants until October 7, 2025. In

support, Appellants show as follows:

1. This motion is unopposed. This is Appellants’ third request for an

extension of time to file their Brief of Appellants.

2. Appellants’ brief is currently due on September 23, 2025 and

Appellants seek a 14-day extension to file their brief until October 7, 2025.

3. This Court has the authority to extend the time to file Briefs of

Appellant under Tex. R. App. P. 38.6(d).

4. The Appellants need additional time to fully brief the issues and

requests this extension due to trial court proceedings, appellate matters, and

unanticipated family obligations that have required the substantial attention of

counsel for Appellants, necessitating this request for additional time.

5. In addition to the listing hereinbelow, the undersigned had a personal

emergency on the morning of Friday September 19th which adversely impacted his

availability to finalize the briefing in this matter.

a. Responsive deadline on August 6, 2025 in JP-8 Comm, LLC, et al. v.
Alford, et al., No. 429-03896-2021, pending in the 429th District Court
of Collin County;

2 | Pa g e
b. Hearing on August 7, 2025 in Graff Chevrolet, et al. v. Tyre Jamir
Griffin, No. DC-25-006855, pending in the 116th District Court of
Dallas County;
c. Pre-trial deadlines on August 8, 2025 in Petryliene, et al. v. Phillips, et
al., No. DC-20-12534, 191st District Court of Dallas County;
d. Responsive deadline on August 8, 2025 in Pack Properties XIV, LLC
v. Remington Prosper, LLC, No. 471-04301-2021, pending in the 471st
District Court of Dallas County;
e. Hearing on August 13, 2025 in JP-8 Comm, LLC, et al. v. Alford, et al.,
No. 429-03896-2021, pending in the 429th District Court of Collin
County;
f. Hearing on August 14, 2025 in Petryliene, et al. v. Phillips, et al., No.
DC-20-12534, 191st District Court of Dallas County;
g. Appellate deadline on August 15, 2025 in White Nile Software, Inc. v.
Carrington Coleman Sloman & Blumenthal, LLP, No. 05-25-01025-
CV pending in the Fifth Texas Court of Appeals at Dallas;
h. Pleading deadline on August 19, 2025 in Expert Services, Inc. v.
Autonomous-Buildings, LLC, et al., No. DC-24-19795, pending in the
134th District Court of Dallas County;
i. Appellate deadline on August 20, 2025 in White Nile Software, Inc. v.
Carrington Coleman Sloman & Blumenthal, LLP, No. 05-25-01025-
CV pending in the Fifth Texas Court of Appeals at Dallas;
j. Hearing on August 20, 2025 in Service Steel Warehouse Co., LP v.
Prime Development Partners, LLC, No. 21-6010-442, pending in the
442nd District Court of Denton County;
k. August 21-26, 2025 – travel out-of-state to address new diagnosis of
elderly parent;
l. Appellate deadline on August 22, 2025 in White Nile Software, Inc. v.
Carrington Coleman Sloman & Blumenthal, LLP, No. 05-25-01025-
CV pending in the Fifth Texas Court of Appeals at Dallas;
m. Briefing deadline on August 22, 2025 in de Monserat, et al. v. Winter
Sun Management, Inc., et al., No. 05-24-01506-CV, pending in the 5th
Texas Court of Appeals at Dallas;

3 | Pa g e
n. Pleading deadline on August 25, 2025 in Expert Services, Inc. v.
Autonomous-Buildings, LLC, et al., No. DC-24-19795, pending in the
134th District Court of Dallas County;
o. Pleading deadline on August 26, 2025 in Expert Services, Inc. v.
Autonomous-Buildings, LLC, et al., No. DC-24-19795, pending in the
134th District Court of Dallas County;
p. Responsive deadline on August 27, 2025 in SRS Distribution, Inc. v.
Dyer, et al., No. CV-2025-01181, pending in the County Court at Law
No. 2 of Denton County;
q. Trial on August 28, 2025 in Edwards v. Jones, et al., No. JPC-24-
02042-52, pending in the Justice Court Precinct 5, Place 2 of Dallas
County;
r. Pretrial deadlines on August 29, 2025 in Petryliene, et al. v. Phillips, et
al., No. DC-20-12534, 191st District Court of Dallas County;
s. Monday, September 1, 2025 was the Labor Day holiday;
t. Discovery deadline on September 3, 2025 in Expert Services, LLC v.
Autonomous-Buildings, LLC, et al., No. DC-24-19795, pending in the
134th District Court of Dallas County;
u. JAMS Mediation on September 4, 2025 in Securities & Exchange
Commission v. Barton, No. 3:22-CV-2118, pending in the United States
District Court for the Northern District of Texas;
v. Pretrial deadline on September 4, 2025 in Petryliene, et al. v. Phillips,
et al., No. DC-20-12534, 191st District Court of Dallas County;
w. Jury trial beginning September 8, 2025 in Petryliene, et al. v. Phillips,
et al., No. DC-20-12534, 191st District Court of Dallas County;
x. Responsive deadline on September 10, 2025 in Valdespino v. El
Dorado Motors, No. 01-SC-24-00504, Justice Court Precinct 1, Collin
County;
y. Deposition on September 11, 2025 in Expert Services, LLC v.
Autonomous-Buildings, LLC, et al., No. DC-24-19795, pending in the
134th District Court of Dallas County;

4 | Pa g e
z. Pretrial deadlines on September 12, 2025 in ABC Land & Development,
Inc., et al. v. Moos, No. DC-23-00403, 68th District Court of Dallas
County;
aa. Pretrial on September16, 2025 in Service Steel Warehouse Co., LP v.
Prime Development Partners, LLC, No. 21-6010-442, pending in the
442nd District Court of Denton County;
bb. Mediation on September 22, 2025 in Liberty Bankers Life Ins. Co. v.
North Texas Fiber, No. DC-25-03284, pending in the 68th District
Court of Dallas County;
cc. Deposition on September 23, 2025 in Expert Services, LLC v.
Autonomous-Buildings, LLC, et al., No. DC-24-19795, pending in the
134th District Court of Dallas County; and
dd. Trial on September 24, 2025 in Service Steel Warehouse Co., LP v.
Prime Development Partners, LLC, No. 21-6010-442, pending in the
442nd District Court of Denton County.
WHEREFORE, Appellants request an 14-day enlargement of time, up to and

including October 7, 2025, in which to file their Brief of Appellants.

Respectfully Submitted

/s/ Mitchell Madden
Mitchell Madden
State Bar No. 12789350
mmadden@hjmmlegal.com
skinney@hjmmlegal.com
Melissa Johnson
State Bar No. 19142900
Email: Melissa@hjmmlegal.com
Holmgren Johnson: Mitchell Madden, LLP
12801 North Central Expressway
Suite 140
Dallas, Texas 75243
(972) 484-7780
ATTORNEYS FOR APPELLANTS

5 | Pa g e
CERTIFICATE OF CONFERENCE

I certify that I conferred with counsel for Appellees on September 22, 2025,
regarding the relief requested in this Motion. Appellees are unopposed.

/s/ Mitchell Madden
Mitchell Madden

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been served
on opposing counsel via e-filing on September 22, 2025.

/s/ Mitchell Madden
Mitchell Madden

6 | Pa g e
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.

Tania Flores on behalf of Mitchell Madden
Bar No. 12789350
tflores@hjmmlegal.com
Envelope ID: 105927643
Filing Code Description: Motion
Filing Description: Third Unopposed Motion for Extension of Time to File
Brief of Appellants
Status as of 9/23/2025 7:03 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

tania flores tflores@hjmmlegal.com 9/22/2025 5:02:32 PM SENT

Mitchell Madden Mmadden@hjmmlegal.com 9/22/2025 5:02:32 PM SENT

Shawnte Kinney skinney@hjmmlegal.com 9/22/2025 5:02:32 PM SENT

Melissa Johnson Melissa@hjmmlegal.com 9/22/2025 5:02:32 PM SENT

Ryan D.Marrone rmarrone@fbfk.law 9/22/2025 5:02:32 PM SENT

John D.Fraser jfraser@fbfk.law 9/22/2025 5:02:32 PM SENT

Luc J.Whyte lwhyte@fbfk.law 9/22/2025 5:02:32 PM SENT