Prescription Health Network, LLC, and William M. Blackshear, Jr. M.D. v. Toby R. Adams, Lisa B. Adams, and Adams Marketing Consulting, Inc.

ACCEPTED 02-15-00279-CV SECOND COURT OF APPEALS FORT WORTH, TEXAS 12/18/2015 10:28:34 AM DEBRA SPISAK CLERK NO. 02-15-00279-CV FILED IN 2nd COURT OF APPEALS FORT WORTH, TEXAS IN THE COURT OF APPEALS 12/18/2015 10:28:34 AM FOR THE SECOND DISTRICT OF TEXAS DEBRA SPISAK FORT WORTH, TEXAS Clerk PRESCRIPTION HEALTH NETWORK, LLC AND WILLIAM M. BLACKSHEAR, JR., M.D. Appellants, v. TOBY R. ADAMS, LISA B. ADAMS AND ADAMS MARKETING CONSULTING, INC. Appellees. ON APPEAL FROM THE ND 442 JUDICIAL DISTRICT COURT, DENTON COUNTY, TEXAS CAUSE NO. 2013-50459-367 APPELLANTS’ PRESCRIPTION HEALTH NETWORK, LLC AND WILLIAM M. BLACKSHEAR, JR., M.D. MOTION FOR EXTENSION OF TIME TO FILE BRIEF Thomas Jacks David W. Green State Bar No. 24067681 State Bar No. 08347475 HARTLINE DACUS BARGER DREYER L.L.P. HARTLINE DACUS BARGER DREYER L.L.P. 8750 N. Central Expressway, Suite 1600 1980 Post Oak Blvd., Suite 1800 Dallas, Texas 75231 Houston, Texas 77056 Telephone: 214-369-2100 Telephone: 713-759-1990 Facsimile: 214-369-2118 Facsimile: 713-652-2419 Email: tjacks@hdbdlaw.com Email: dgreen@hdbdlaw.com COUNSEL FOR APPELLANTS APPELLANTS’ MOTION FOR EXTENSION OF TIME TO FILE BRIEF (UNOPPOSED) Pursuant to Rule 10.5(b) of the Texas Rules of Appellate Procedure, Appellants Prescription Health Network, LLC and William M. Blackshear, Jr., M.D. asks this Court to extend the time to file its Brief and would show as follows: 1. Appellees are Toby R. Adams, Lisa B. Adams, and Adams Marketing Consulting, Inc. 2. This motion is filed before the deadline for filing the Brief of Appellants, as required by Texas Rule of Appellate Procedure 38.6(d). 3. Appellants’ Brief is currently due on December 30, 2015. 4. Appellants request an extension of 30 days to file its Brief, extending the deadline to Friday, January 29, 2016. 5. No previous extensions by Appellants have been requested. 6. Appellants request an extension of time in which to file its Brief in order to allow time to adequately prepare its brief to aid the Court in consideration of this appeal. In support of this motion, Appellants would state the following: • Over the past month, the undersigned counsel has taken over litigation involving an $8,000,000.00 construction case claim and other litigation following the departure of one of our firm’s attorneys in mid-November who was handling the cases. These cases have required the immediate attention of the undersigned counsel during the past month in addition to other matters; • Over the past several weeks, counsel has been out of town and out of state with regard to hearings and other related matters; • Over the past several months, our firm’s offices have undergone the installation of an entire new case/document management system which has, to this point, required additional time for training and issues related to the use and integration of the system from prior practice; 2 • Counsel plans to be out of town for portions of the upcoming holidays including travel to San Antonio and Beaumont which will decrease time available. 7. The undersigned has spoken with Mary Nix, counsel for the Appellees, who does not oppose this motion. WHEREFORE, PREMISES CONSIDERED, Appellants Prescription Health Network, LLC and William M. Blackshear, Jr., M.D. request this Honorable Court grant this Motion for Extension of Time until January 29, 2016, and award such further relief to which it may be entitled. CERTIFICATE OF CONFERENCE I hereby certify that on this day, December 18th, 2015, I have conferred with opposing trial and appellate counsel, Mary Nix, and she does not oppose the foregoing Appellants’ Motion for Extension of Time to File Appellants’ Brief until January 29, 2016. /s/ David W. Green David W. Green CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon counsel as indicated below on this 18th day of December, 2015. Mary Goodrich Nix HOLLAND & KNIGHT LLP 200 Crescent Court, Suite 1600 Dallas, Texas 75201 /s/ David W. Green David W. Green 3