Motion to Extend Time to File Appeallant Brief

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CIVIL ACTION NO. 3:13-cv-04644-L 
 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF TEXAS 
Dallas Division 
 
 
JEFFREY BARON, 
Appellant 
 
v. 
DANIEL SHERMAN, et. al. 
Appellees 
ON APPEAL FROM THE UNITED STATES BANKRUPTCY COURT 
FOR THE NORTHERN DISTRICT OF TEXAS 
Dallas Division 
 
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF 
 
  Appellant, Jeffrey Baron, hereby requests the Court grant an order extending the time for 
filing of Appellant’s brief in the above captioned matter and, in support thereof  states: 
1.  The appeal of this matter was docketed and the record transmitted to this Court on 
November 21, 2013. 
2.  A continuance is requested due to counsel’s heavy deposition and trial schedule.  Counsel 
has also been involved as a principal lawyer and party in conducting the due diligence for 
a transaction involving restructuring of a corporation that must be completed by the end 
of December, 2013 and preferably before his pre-paid scheduled vacation. 
3.  Counsel has a pre-paid vacation to Salt Lake City, Utah to visit family for the holidays 
starting on December 19, 2013 through December 27, 2013. 
4.  Counsel is a solo practitioner and has depositions on January 2-4, 2014 and therefore 
requests that the Court allow Appellant up to and including January 9, 2014 to file his 
Case 3:13-cv-04644-L   Document 2   Filed 12/06/13    Page 1 of 2   PageID 988

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appellate brief. 
5.  Counsel is unable to submit an acceptable brief prior to Thursday, January 9, 2014.   A 
shorter briefing schedule will work hardship on counsel for appellant. 
Respectfully submitted, 
 
  /s/ Stephen R. Cochell 
Stephen R. Cochell 
The Cochell Law Firm, P.C. 
Texas Bar No. 24044255 
7026 Old Katy Rd., Ste 259 
Houston, Texas 77096 
(713)980-8796 (phone) 
(713)980-1179 (facsimile) 
srcochell@cochellfirm.com 
6.   
 
CERTIFICATE OF CONFERENCE 
This is to certify that counsel for Appellant requested an extension of time by email dated 
December 4, 2013 and at the time of filing this motion, had not received a response to the request 
therefore presuming the motion to be presumed. 
        s/s Stephen R. Cochell 
       s/s Stephen R. Cochell 
 
CERTIFICATE OF SERVICE 
  This is to certify that the above document has been served on all counsel of record by the 
Court’s cm/ecf system and has also been served on John Litzler, Trustee, In re Jeffrey Baron, 
Case No. 12-37921-sgj7, United States District Court, Northern District of Texas by United 
States mail at the following address: 
John Litzler 
Trustee 
1412 Main St Ste 2400 
Dallas, Texas 75202           
         s/s Stephen R. Cochell 
        s/s Stephen R. Cochell 
Case 3:13-cv-04644-L   Document 2   Filed 12/06/13    Page 2 of 2   PageID 989