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Frankie Marie Miller, Individually and as Representative of the Estate of T.J. Miller v. John B. Mullen, M.D., and Titus Regional Medical Center
06-15-00059-CV
| Tex. Crim. App. | Nov 9, 2015
|
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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

Case Details

Case Name: Frankie Marie Miller, Individually and as Representative of the Estate of T.J. Miller v. John B. Mullen, M.D., and Titus Regional Medical Center
Court Name: Court of Criminal Appeals of Texas
Date Published: Nov 9, 2015
Docket Number: 06-15-00059-CV
Court Abbreviation: Tex. Crim. App.
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