Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 11/9/2015 11:00:56 AM DEBBIE AUTREY Clerk *1 ACCEPTED 06-15-00059-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 11/9/2015 11:00:56 AM DEBBIE AUTREY CLERK NO. 06-15-00059-CV ______________________________________________________
IN THE SIXTH DISTRICT COURT OF APPEALS TEXARKANA, TEXAS ______________________________________________________
Frankie Marie Miller, Individually and as Representative of the Estate of T.J. Miller, Appellant, v.
John D. Mullen, M.D. and Titus Regional Medical Center, Appellees.
______________________________________________________
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF ______________________________________________________
TO THE HONORABLE COURT OF APPEALS:
1. Appellant’s Brief is due on November 12, 2015. Appellant seeks a 21-
day extension to make the brief due on December 3, 2015.
2. This is the first request for an extension.
3. The record was filed in this case on October 12, 2015. Between
October 12 and November 12, the undersigned has had or will have two oral
arguments in the Supreme Court of Texas and another in the Texas Court of
Criminal Appeals, and two petitions for review due in the Texas Supreme Court.
This is in addition to the ordinary workload of counsel (which includes a reply brief
in the El Paso Court of Appeals, appellees’ brief in the Dallas Court of Appeals,
appellee’s brief in the Fort Worth Court of Appeals, and appellant’s brief in the
Fort Worth Court of Appeals).
4. Appellee does not oppose this motion.
Based on the foregoing, Appellant asks that the deadline to file her brief be
extended to December 3, 2015.
Respectfully submitted, The Law Office of Chad Baruch Texas Bar Number 01864300 3201 Main Street Rowlett, Texas 75088 Telephone: (972) 412-7192 Facsimile: (972) 412-4028 E-Mail: baruchEsq@aol.com Attorney for Appellant *3 CERTIFICATE OF CONFERENCE The undersigned certifies that he conferred with Russell Schell, counsel for
appellee, who stated that he does not oppose the relief sought by this motion.
/s/Charles “Chad” Baruch CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of this notice of appeal was
served this 9th day of November, 2015, upon the following counsel of record by
efiling and email:
Russell W. Schell
Schell Cooley LLP
15455 Dallas Parkway, Suite 550
Addison, Texas 75001
Trial Counsel for Appellees
rschell@schellcooley.com
vbrumley@schellcooley.com
shaley@schellcooley.com
