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
1/6/2026 5:04 PM
NO. 15-25-00055-CV CHRISTOPHER A. PRINE
CLERK

In The Court of Appeals for the 15th 15th
District
FILED IN
COURT OF APPEALS
Of Texas at Austin, Texas 1/6/2026 AUSTIN, TEXAS
5:04:29 PM
__________________________________________________________________
CHRISTOPHER A. PRINE
Clerk
FRISCO SUMMIT, LP AND FRISCO SUMMIT, LP DERIVATIVELY 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
__________________________________________________________________

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

Mitchell Madden
State Bar No. 12789350
mmadden@thelomm.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 30-day extension of time to file their Reply Brief of Appellants until February 18,

2026. In support, Appellants show as follows:

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

extension of time to file their Reply Brief of Appellants.

2. Appellee’s Brief was submitted on December 23, 2025, but not file-

marked until a corrected version of the brief was filed on December 29, 2025.

Therefore, Appellants’ brief is due on January 19, 2026 and Appellants seek a 30-

day extension to file their brief until February 18, 2026.

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 pending trial and appellate matters that require

substantial time, and a 2-week specially set trial beginning January 12, 2026.

Moreover, Appellants also have the following matters and deadlines that will take

substantial time:

a. Pleading deadline on January 5, 2026 in Liberty Bankers Life Ins. Co.
v. Work of Art Medical & Wellness Care, PLLC, et al., No. DC-25-
21098, District Court of Dallas County;
b. Discovery deadline on January 5, 2026 in Black Sheep Holdings, LLC
v. Lone Star Kinetics Holdings, Inc., No. 25-12701-442, District Court
of Denton County;
2 | Pa g e
c. Docket call on January 5, 2026 in Dyer, et al. v. Geeting, et al., No. 16-
05937-393, District Court of Denton County;
d. Responsive deadline on January 7, 2026 in Aguilar v. Liberty Bankers
Life Insurance Company, No. 4:25-CV-04990, United States District
Court for the Southern District of Texas, Houston Division;
e. Hearing on January 7, 2026 in Liberty Bankers Life Ins. Co. v. Work of
Art Medical & Wellness Care, PLLC, et al., No. DC-25-21098, District
Court of Dallas County;
f. Deposition on January 7, 2026 in Lone Star Kinetics Holdings, Inc. v.
Native Trading Company LLC, et al., No. DC-25-06981, District Court
of Dallas County;
g. Appellate deadline on January 9, 2026 in Remington Prosper, LLC v.
Pack Properties XIV, LLC, et al., No. 05-25-01710-CV, 5th Court of
Appeals at Dallas;
h. Responsive deadline on January 12, 2025 in Graff Chevrolet v. Griffin,
No. DC-25-06855, District Court of Dallas County;
i. Responsive deadline on January 12, 2026 in Aguilar v. Liberty Bankers
Life Insurance Company, No. 4:25-CV-04990, United States District
Court for the Southern District of Texas, Houston Division;
j. 2-week specially set trial begins on January 12, 2026 in Dyer, et al. v.
Geeting, et al., No. 16-05937-393, District Court of Denton County;
k. Expert deadline on January 14, 2026 in Graff Chevrolet v. Griffin, No.
DC-25-06855, District Court of Dallas County;
l. Pretrial and scheduling conference on January 15, 2026 in Aguilar v.
Liberty Bankers Life Insurance Company, No. 4:25-CV-04990, United
States District Court for the Southern District of Texas, Houston
Division;
m. Hearing on January 15, 2026 in Graff Chevrolet v. Griffin, No. DC-25-
06855, District Court of Dallas County;
n. Expert and pleading deadlines on January 16, 2026 in Nexen v.
Southern Tire Mart, No. 01-25-0002-8179, American Arbitration
Association;
o. Responsive deadline on January 23, 2026 in Nexen v. Southern Tire
Mart, No. 01-25-0002-8179, American Arbitration Association;
p. Pleading deadline on January 23, 2026 in Liberty Bankers Life Ins. Co.
v. North Texas Fiber, Inc., No. DC-25-03284, District Court of Dallas
County; and
q. Responsive deadline on January 28, 2026 in Black Sheep Holdings,
LLC v. Lone Star Kinetics Holdings, Inc., No. 25-12701-442, District
Court of Denton County.
3 | Pa g e
WHEREFORE, Appellants request a 30-day enlargement of time, up to and

including February 18, 2026, in which to file their Reply 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
Dennis M. Holmgren
State Bar No. 24036799
Email: Dennis@hjmmlegal.com
Holmgren Johnson: Mitchell Madden, LLP
12801 North Central Expressway
Suite 140
Dallas, Texas 75243
(972) 484-7780
(972) 484-7743 Facsimile

ATTORNEYS FOR APPELLANTS

CERTIFICATE OF CONFERENCE

I certify that I conferred with counsel for Appellees on January 6, 2026
regarding the relief requested in this Motion. Appellees are unopposed.

/s/ Mitchell Madden
Mitchell Madden

4 | Pa g e
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 January 6, 2026.

/s/ Mitchell Madden
Mitchell Madden

5 | 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: 109728564
Filing Code Description: Motion
Filing Description: Unopposed Motion for Extension of Time
Status as of 1/7/2026 7:10 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

William NDrabble wdrabble@grayreed.com 1/6/2026 5:04:29 PM SENT

tania flores tflores@thelomm.com 1/6/2026 5:04:29 PM SENT

Jim Moseley jmoseley@grayreed.com 1/6/2026 5:04:29 PM SENT

Joe W.Beverly jb@fbfk.law 1/6/2026 5:04:29 PM SENT

Staci Bednarski sbednarski@fbfk.law 1/6/2026 5:04:29 PM SENT

Christi Lillie clillie@grayreed.com 1/6/2026 5:04:29 PM SENT

Ryan D.Marrone rmarrone@fbfk.law 1/6/2026 5:04:29 PM SENT

John D.Fraser jfraser@fbfk.law 1/6/2026 5:04:29 PM SENT

Luc J.Whyte lwhyte@fbfk.law 1/6/2026 5:04:29 PM SENT

GayLynn Dwyer gdwyer@fbfk.law 1/6/2026 5:04:29 PM SENT

Melissa Johnson Melissa@thelomm.com 1/6/2026 5:04:29 PM SENT

Mitchell Madden mmadden@thelomm.com 1/6/2026 5:04:29 PM ERROR