Case Information

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No. 01-12-00578-CV In the First Court of Appeals Filed in Houston, Texas 1st COURT OF APPEALS HOUSTON, TEXAS 3/5/2015 12:19:59 PM

CHRISTOPHER A: PRINE Clerk

JIM P. BENGE, MD AND Kelsey-SeYbold Medical Group Pllc Defendants/Appellants V.

LAUREN WILLIAMS Plaintiff/ApPELLEE

On Appeal from the 164th District Court Harris County, Texas No. 2010-52657

Appellants' Unopposed Motion for Extension of Time to File Responses to Motions for Rehearing and En Banc Reconsideration

David George
Texas Bar No. 00793212
Earnest W. Wotring
Texas Bar No. 22012400
Amy Nilsen
Texas Bar No. 24027574
Connelly $·$ BaKer $·$ Wotring LlP
700 JPMorgan Chase Tower
600 Travis Street
Houston, Texas 77002
Telephone: (713) 980-6513
Fax: (713) 980-1701
dgeorge@connellybaker.com
Counsel for Appellants

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Pursuant to Texas Rules of Appellate Procedure 10.5(b), Appellants Jim Benge, MD and Kelsey-Seybold Medical Group, PLLC (collectively, "Kelsey") request a two-week extension of the due date on their responses to Appellee Lauren Williams' motions for rehearing and en banc reconsideration, which are currently due on March 18, 2015. Williams does not oppose this request.

David George is Kelsey's attorney who is drafting the response to the motions. His work in other cases makes it difficult for him to complete the responses by March 18, 2015. George has a brief that is due in the Fifth Circuit on March 23, 2015, and that due date cannot be extended. ^[1] Another attorney in George's firm was handling that case, but she recently left the firm. George, therefore, is having to review the entire case to be in a position to properly draft the brief. That, of course, is taking additional time and interferes with his ability to draft the responses to Williams' motions by March 18.

Kelsey, therefore, requests that this Court extend the due date for its responses to Williams' motions for rehearing and en banc reconsideration by two weeks, which is until Wednesday, April 1, 2015.

*3 Respectfully submitted, Is/ David George David George Texas Bar No. 00793212 Earnest W. Wotring Texas Bar No. 22012400 Amy Nilsen Texas Bar No. 24027574 CONNELLY・BAKER・WOTRING LLP 700 JPMorgan Chase Tower 600 Travis Street Houston, Texas 77002 Telephone: (713) 980-6513 Fax: (713) 980-1701 dgeorge@connellybaker.com Counsel for Appellants

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CERTIFICATE OF CONFERENCE

I certify that on March 4, 2015, I conferred via e-mail with Appellee's counsel Lucy Forbes. She informed me that she does not oppose the Court granting the relief requested in this motion. /s/ David George David George

CERTIFICATE OF SERVICE

I certify that on March 5, 2015, I served a copy of the foregoing document upon the following counsel of record by e-mail and certified mail/return receipt requested:

Lucy H. Forbes The Forbes Firm, pllc 2114 Woodcrest Drive Houston, Texas 77018 lucy@forbesfirm.com Randall O. Sorrels Abraham, Watkins, Nichols, Sorrels, Agosto &; Friend 800 Commerce Street Houston, Texas 77002 rsorrels@abrahamwatkins.com /s/ David George David George

NOTES

${}^1$ Kelsey-Seybold Medical Group PA v. Great-West Healthcare of Tex., Inc., No. 1420506 (5th Cir.).