ACCEPTED
03-16-00301-CV
12697356
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/14/2016 1:29:49 PM
JEFFREY D. KYLE
CLERK
CAUSE NO. 03-16-00301-CV
FILED IN
3rd COURT OF APPEALS
In the Court of Appeals for the Third Judicial District AUSTIN, TEXAS
At Austin, Texas 9/14/2016 1:29:49 PM
JEFFREY D. KYLE
Clerk
MARGARET REID,
Appellant,
v.
SETON HOSPITAL, MICHAEL BREEN, AND ANN CZARNIK
Appellees
ON APPEAL FROM THE 53RD DISTRICT COURT
TRAVIS COUNTY, TEXAS
CAUSE NO. D-1-G-15-003300
HONARABLE KAREN CRUMP
UNOPPOSED FIRST MOTION TO EXTEND TIME TO FILE BRIEF
OF APPELLEE ANN CZARNIK
BRUSTKERN FLOCOS &ASSOCIATES
Tim Flocos
TX Bar No. 24033697
611 West 14th Street, Suite 200
Austin, Texas 78701
Phone: 512.467.6076
Fax: 512.467.6550
tim@timflocos.com
Attorney for Defendant, Ann Czarnik - Appellee
Attorney for Plaintiff/Appellant Margaret Reid
THE SARFO LAW FIRM
Samuel Adjei Sarfo
TX Bar No. 24071896
1703B Burton Drive
Austin, Texas 78701
Phone: 512.297.0227
Fax: 512.441.3413
Email: lawyersarfo@yahoo.com
Attorney for Defendants’/Appellees Seton Hospital and Michael Breen
Norton Rose Fulbright US LLP
Daphne Andritsos
TX Bar No. 00793266
98 San Jacinto Blvd, Suite 110
Austin, Texas 78701-4225
Phone: 512.536.5412
Fax: 512.536.4598
Email: enmaprice@nortonrosefulbright.com
TO THE HONORABLE JUDGE OF THE THIRD COURT OF APPEALS:
COMES NOW, Appellee Ann Czarnik, and files this her Motion to Extend Time to File
Brief pursuant to Tex. R. App. Proc. 10.5(b) and 38.6(d), and would respectfully show the Court:
1. Appellant is Margaret Reid; Appellees are Seton Hospital, Micheal Breen, and Ann
Czarnik.
2. Counsel for Appellant Reid and counsel for Appellees Seton Hospital and Micheal
Breen are all unopposed to this motion as evidenced in the certificate of conference below.
3. Appellee Czarnik’s response brief on the merits is due to be filed with this Court on
September 15, 2016.
4. Appellees seek a 10-day extension of time to file Appellee’s brief, to September 25,
2016.
5. This is Appellee’s first request to extend time for filing her response brief.
6. Due to unexpected events lead counsel for Appellee has become unavailable during the
time the brief is to be filed.
7. Counsel for Appellee seeks this extension of time to be able to prepare a cogent and
succinct brief to aid this Court in its analysis of the issues presented. This request is not sought
for delay but so that justice may be done.
8. All facts recited in this motion are within the personal knowledge of the counsel
signing this motion, therefore no verification is necessary under Texas Rule of Appellate
Procedure 10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellee requests that this Court grant this First Motion
to Extend Time to File Appellee’s Brief and extend the deadline for filing the Appellee’s Brief
up to and including September 25, 2016.
Respectfully submitted,
____________________________________
Tim Flocos, TX Bar No. 24033697
BRUSTKERN FLOCOS &ASSOCIATES
611 West 14th Street, Suite 200
Austin, Texas 78701
Phone: 512.467.6076
Fax: 512.467.6550
tim@timflocos.com
Attorney for Defendant, Ann Czarnik - Appellee
Certificate of Conference
Pursuant to TEX. R. APP. P. 10.1(5), I certify that the undersigned conferred with
counsel for Plaintiff/Appellant Margaret Reid and counsel for Defendants’/Appellees Seton
Hospital and Michael Breen who indicated that they do not oppose this motion.
Tim Flocos
Certificate of Service
I hereby certify that on September 14th, 2016 a copy of the foregoing Motion to Extend
Time was delivered to the following parties by e-mail and the Court’s E-filing system:
Samuel Adjei Sarfo
TX Bar No. 24071896
THE SARFO LAW FIRM
1703B Burton Drive
Austin, Texas 78701
Phone: 512.297.0227
Fax: 512.441.3413
Email: lawyersarfo@yahoo.com
Attorney for Plaintiff/Appellant Margaret Reid
Daphne Andritsos
TX Bar No. 00793266
Norton Rose Fulbright US LLP
98 San Jacinto Blvd, Suite 110
Austin, Texas 78701-4225
Phone: 512.536.5412
Fax: 512.536.4598
Email: enmaprice@nortonrosefulbright.com
Attorney for Defendants’/Appellees Seton Hospital and Michael Breen
Tim Flocos