Andre McCoy, as Permanent Guardian of Shannon Miles McCoy, an Incapacitated Person v. FemPartners, Inc.

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ACCEPTED 14-14-00754-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/13/2015 1:10:59 PM CHRISTOPHER PRINE CLERK NO. 14-14-00754-CV IN THE COURT OF APPEALS FILED IN 14th COURT OF APPEALS FOR THE FOURTEENTH JUDICIAL DISTRICTHOUSTON, TEXAS OF TEXAS AT HOUSTON 3/13/2015 1:10:59 PM CHRISTOPHER A. PRINE Clerk ANDRE MCCOY, AS PERMANENT GUARDIAN OF SHANNON MILES MCCOY, AN INCAPACITATED PERSON, Appellants, V. FEMPARTNERS, INC., FEMPARTNERS OF CENTRAL HOUSTON, L.P. f/k/a OGA MANAGEMENT PARTNERSHIP, L.P. NEW OGA, INC., PROASSURANCE CORPORATION; AMERICAN PHYSICIANS SERVICES GROUP, INC. AND AMERICAN PHYSICIANS SERVICES GROUP, INC. F/K/A AMERICAN PHYSICIANS INSURANCE COMPANY F/K/A AMERICAN PHYSICIANS INSURANCE EXCHANGE, Appellees. On Appeal from Probate Court Number Two Of Harris County, Texas Trial Court Cause No. 352,923-404 UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEES’ BRIEF STRAWN PICKENS, LLP John R. Strawn, Jr. #19374100 Victoria Skinner #24005579 Pennzoil Place, South Tower 711 Louisiana, Suite 1850 Houston, Texas 77002 jstrawn@strawnpickens.com vskinner@strawnpickens.com ATTORNEYS FOR APPELLEE FemPartners, Inc., FemPartners of Central Houston, L.P., and New OGA, Inc UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF Appellees FemPartners, Inc., FemPartners of Central Houston, L.P. (“Central Houston”), and New OGA, Inc. (collectively “FemPartners”) (“Appellees”) respectfully file this unopposed Second Motion seeking an extension of thirty (30) days to file Appellees’ brief in this matter. Appellees show the following: 1. Appellees are FemPartners, Inc., FemPartners of Central Houston, L.P. (“Central Houston”), and New OGA, Inc. (collectively “FemPartners”); Appellant is Andre McCoy, as permanent guardian of Shannon Miles McCoy, an Incapacitated Person. 2. This motion is filed within any deadline contemplated under Tex. R. App. P. 10.1, 10.5. 3. This Motion for Extension is unopposed. 4. The Court may grant an extension of time under the authority of Tex. R. App. P. 10.5(b). 5. This is an appeal of a summary judgment entered in Probate Court Number Two, Harris County, Texas. The deadline to file Appellees’ brief is March 23, 2015. 2 6. Appellees request an additional thirty (30) days to file their brief, extending the time that the brief is due until April 21, 2015. 7. Appellees do not seek this extension for reasons of delay. Rather, counsel for Appellees have been exceptionally busy with other projects which occupy the time that counsel would ordinarily use to prepare the Appellees’ brief, including but not limited to: • Preparation for and participation in a multi-million dollar complex international arbitrating hearing, Friede & Goldman L.L.C. v HICO America Sales & Technology, Inc. (American Arbitration Association ICDR Case 50 20 1200 0918 2 GM) that ended March 9, 2015; • Preparation for trial in Cause No. 2013-76981; Adam Lefton vs. Northstar Healthcare Acquisitions, L.L.C. and Northstar Healthcare, Inc., in the 11th Judicial District of Harris County, Texas, which had been assigned to trial starting March 30, 2015; and • Counsel has a longstanding family trip scheduled for March 13, 2015 through March 23, 2015. 8. Appellees have sought one prior extension to file their brief in this matter. 9. For the above reasons, Appellees respectfully request the Court grant an extension of time to file Appellees’ brief in this appeal until April 21, 2015. Appellees respectfully request all other appropriate relief. 3 Respectfully submitted, STRAWN PICKENS LLP By: /s/ John R. Strawn Jr. John R. Strawn, Jr., #19374100 Victoria Skinner #24005579 Pennzoil Place, South Tower 711 Louisiana, Suite 1850 Houston, Texas 77002 (713) 659-9600 (713) 659-9601 Facsimile jstrawn@strawnpickens.com vskinner@strawnpickens.com ATTORNEYS FOR APPELLEE FemPartners, Inc., FemPartners of Central Houston, L.P., and New OGA, Inc. CERTIFICATE OF CONFERENCE In accordance with TEX. R. APP. P. 10.1(a)(5), the undersigned counsel has contacted counsel for Appellant and Appellant is unopposed to the Motion For Extension of Time To File Appeelles’ Brief. /s/ John R. Strawn, Jr. John R. Strawn, Jr. 4 CERTIFICATE OF SERVICE I, John R. Strawn, Jr., hereby certify that a true and correct copy of the foregoing instrument has been provided to all counsel of record in accordance with the applicable Texas Rules of Appellate Procedure on this 13th day of March 2015. Alexander B. Klein, III J. Todd Trombley Email: alex@thekleinlawfirm.com Email: todd@trombleylaw.com THE KLEIN LAW FIRM THE TROMBLEY LAW FIRM, 2000 The Lyric Centre P.L.L.C. 440 Louisiana Street 442 Heights Boulevard Houston, Texas 77002 Houston, Texas 77007 Tynan Buthod Email: ty.buthod@bakerbotts.com Brandon Goodwin Email:Brandon.goodwin@bakerbotts.com BAKER BOTTS, L.L.P. One Shell Plaza 910 Louisiana Street Houston, Texas 77002 /s/ John R. Strawn, Jr. John R. Strawn, Jr. 5