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.
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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.
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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.
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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.
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