ACCEPTED
05-14-01464-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
6/17/2015 9:53:40 AM
LISA MATZ
CLERK
NO. 05-14-01464-CV
FILED IN
IN THE FIFTH DISTRICT COURT OF APPEALS
5th COURT OF APPEALS
DALLAS DIVISION DALLAS, TEXAS
6/17/2015 9:53:40 AM
LISA MATZ
Clerk
SHERI DURHAM and DENISE JENKINS, as Administrator
of the Estate of Jessica Haley Durham,
Appellants,
V.
CHILDREN’S MEDICAL CENTER OF DALLAS, AMY HOLLAND, CPNP,
DAVID KINES, FNP, LAWSON COPLEY, M.D., J. PATRICK HIEBER, M.D.,
and TIMOTHY RUPP, M.D.,
Appellees.
APPELLANTS’ UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE REPLY BRIEF
Appellants Sheri Durham and Denise Jenkins, as Administrator of the Estate of
Jessica Haley Durham (“Appellants”), file this Unopposed Motion for Extension of Time to
File their Reply Brief, and in support respectfully show as follows:
1. The deadline for the filing of Appellants’ Reply Brief is June 29, 2015.
2. Appellants seek an extension of this deadline for twenty-one (21) days, or until
July 20, 2015.
APPELLANTS’ UNOPPOSED M OTION FOR
EXTENSION OF TIM E TO FILE REPLY BRIEF Page 1
3. The extension is required due to previously scheduled trials and other deadlines
making Appellants’ counsel unavailable to complete and file the brief by the current
deadline.
4. This is Appellants’ first request for an extension of this particular filing
deadline.
WHEREFORE, PREMISES CONSIDERED, Appellants respectfully request that the
Court extend the deadline for the filing of Appellants’ Reply Brief for a period of twenty-one
(21) days or until July 20, 2015.
Respectfully submitted,
/s/ Carrie P. Kitner
Kenneth B. Chaiken
State Bar No. 04057800
kchaiken@chaikenlaw.com
Robert L. Chaiken
State Bar No. 04057830
rchaiken@chaikenlaw.com
Carrie P. Kitner
State Bar No. 24074921
ckitner@chaikenlaw.com
C HAIKEN & C HAIKEN, P.C.
Legacy Town Center III
5801 Tennyson Parkway, Suite 440
Plano, Texas 75024
(214) 265-0250 telephone
(214) 265-1537 facsimile
ATTORNEYS FOR APPELLANTS
APPELLANTS’ UNOPPOSED M OTION FOR
EXTENSION OF TIM E TO FILE REPLY BRIEF Page 2
CERTIFICATE OF CONFERENCE
I hereby certify that on June 16, 2015, I conferred with counsel for the Appellees
regarding the items to be presented to the Court in this motion. All counsel stated that they
are not opposed to the relief requested.
/s/ Carrie P. Kitner
Carrie P. Kitner
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this Unopposed Motion for Extension
of Time to File Appellants’ Reply Brief has been served upon counsel for Appellees via
electronic service and/or e-mail on the 17 th day of June, 2015.
/s/ Carrie P. Kitner
Carrie P. Kitner
APPELLANTS’ UNOPPOSED M OTION FOR
EXTENSION OF TIM E TO FILE REPLY BRIEF Page 3
Sheri Durham and Denise Jenkins, as Administrator of the Estate of Jessica Haley Durham v. Children's Medical Center of Dallas, Amy Holland, CPNP, David W. Kines, FNP, Lawson Copley, M.D., J. Patrick Hieber, M.D. and Timothy J. Rupp, M.D.
Combined Opinion