Case Information
*1 ACCEPTED 14-14-00379-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/11/2015 12:37:05 PM CHRISTOPHER PRINE CLERK NO. 14-14-00379-CV In the Court of Appeals for the FOURTEENTH DISTRICT OF TEXAS
ROSALINDA REYES A PPELLANT V .
MEMORIAL HERMANN HEALTH SYSTEM D/B/A TIRR MEMORIAL
HERMANN A PPELLEE On Appeal from the 129th District Court, Harris County, Texas, Cause No. 2013-35690,
The Hon. Michael Gomez, Judge Presiding UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF TO THE HONORABLE COURT OF APPEALS:
COMES NOW, Memorial Hermann Health System d/b/a TIRR Memorial Hermann and files this Unopposed Motion to Extend Time to File Appellee’s Brief. In support of this Motion, Appellee shows unto this Court the following:
A. INTRODUCTION This is an interlocutory appeal brought by Appellant pursuant to the Texas Civil Practice & Remedies Code Section 51.014(a)(9), which allows an *2 interlocutory appeal from an order denying a motion to dismiss under Texas Civil Practice & Remedies Code Section 74.351 (b). The Appellant is Rosalinda Reyes and the Appellee is Memorial Hermann Health System d/b/a Memorial Hermann TIRR.
B. ARGUMENT & AUTHORITIES 2. No rule limits the time within which to file this Motion to Extend.
Tex. R. App. P. 38.6. The Court may extend time to file Appellee’s Brief under the
authority of Tex. R. App. P. 38.6(d).
4. Appellee’s Brief is due on or about February 16, 2015. 5. Appellee requests an additional thirty (30) days from the current due date in which to file its brief, extending the time to March 16, 2015.
6. Appellee has previously requested two extensions to file its brief.
7. An extension of time to file Appellee’s Brief would allow Appellee to prepare its brief with the thoughtful consideration and deliberation that this important matter requires.
PRAYER For these reasons, Appellee asks the Court to grant an extension of time to file its Brief to March 16, 2015.
Respectfully submitted, LUCCIA & EVANS, L.L.P. By /s/ Frank N. Luccia Frank N. Luccia SBN 12664400 fnluccia@luccia-evans.com Mary M. Wagner SBN 20659920 mmwagner@luccia-evans.com 8 Greenway Plaza, Suite 1450 Houston, Texas 77046 (713) 629-0002 / Fax (713) 629-0004 ATTORNEYS FOR APPELLEE CERTIFICATE OF CONFERENCE
I hereby certify that we have conferred with counsel for Appellant regarding the foregoing motion and opposing counsel is unopposed.
*4 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing Motion to Extend Time to File Appellee’s Brief has been forwarded to counsel for Appellant via [ ] facsimile, [ ] certified mail, return receipt requested, [X] e-service on the 11 th day of February, 2015 as follows:
Kevin Adley
Gilbert Garza
ADLEY LAW FIRM LTD, LLP
1421 Preston St.
Houston, TX 77002